SOUTHERN RESEARCH
Legendary Discoveries. Leading Innovation.
               DEMONSTRATION PLAN
      Demonstration and Verification of a Turbine Power
    Generation System Utilizing Renewable Fuel: Landfill
                                              Gas

                  SERDP/ESTCP Project #EW-200823
        EPA ETV Document SRI/USEPA-GHG-QAP-50
             Southern Research Institute Project #12704

                                    February, 2011
                                            Final
                   Principal Investigator: Tim Hansen

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                                       RE VIEW NOTICE
This report has been peer  and administratively  reviewed  by Southern Research  Institute,  the U.S.
Environmental Protection Agency and the U.S. Department of Defense ESTCP program, and approved for
publication.   Mention of  trade  names or  commercial products  does not constitute endorsement  or
recommendation for use.

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            Greenhouse Gas Technology Center
       A U.S. EPA Sponsored Environmental Technology Verification Organization
      Demonstration and Verification of a Turbine Power
  Generation  System Utilizing Renewable Fuel: Landfill Gas
This Demonstration/Test and Quality Assurance Plan has been reviewed and approved by the Greenhouse Gas
Technology Center Project Manager, Quality Assurance Manager and Center Director; the U.S. Department of
Defense ESTCP EW Program Manager; and the U.S. EPA APPCD Project Officer and Quality Assurance
Manager.  Work was funded under ESTCP Project EW2008-23.
Tim Hansen       Signed February 2011
Principal Investigator
Director,
Greenhouse Gas Technology Center
Southern Research Institute
Dr. James Galvin    Signed February 2011
Active Program Manager - Energy & Water
ESTCP
U.S. Department of Defense
Eric Ringler       Signed February 2011
Quality Assurance Manager
Greenhouse Gas Technology Center
Southern Research Institute
Lee Beck         Signed February 2011
APPCD Project Officer
U.S. EPA
                                            Robert Wright     Signed February 2011
                                            APPCD Quality Assurance Manager
                                            U.S. EPA

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Table of Contents

List of Tables	iii
List of Figures	iii
List of Acronyms	iv
1.0 INTRODUCTION	1
   1.1 Background	1
   1.2 Objective Of The Demonstration	2
   1.3 Drivers	2
2.0 TECHNOLOGY DESCRIPTION	2
  2.1 Technology Overview	2
  2.2 Advantages and Limitations of the Technology	4
3.0 PERFORMANCE OBJECTIVES	5
  3.1 Power Production and Quality	7
     3.1.1 Metric and Data Requirements	7
     3.1.2 Success Criteria	7
  3.2 Emissions	8
     3.2.1 Metric and Data Requirements	8
     3.2.2 Success Criteria	8
  3.3 Destruction Efficiency	9
     3.3.1 Metric and Data Requirements	9
     3.3.2 Success Criteria	9
  3.4 Greenhouse Gas Reductions	10
     3.4.1 Metric and Data Requirements	10
     3.4.2 Success Criteria	10
  3.5 Economics	11
     3.5.1 Metric and Data Requirements	11
     3.5.2 Success Criteria	11
  3.6Operability	11
     3.6.1 Metric and Data Requirements	11
     3.6.2 Success Criteria	12
4.0 FACILITY/SITE DESCRIPTION	12
  4.1 Facility/Site Selection	12
  4.2 Facility/Site Location, Operations and Conditions	13
  4.3 Site-Related Permits and Regulations	16
5.0 TEST DESIGN	17
  5.1 Conceptual Test Design	17
  5.2 Baseline Characterization	17
  5.3 Design and Layout of Technology Components	18
  5.4 Operational Testing	19
     5.4.1 Acceptance Test	20
     5.4.2 Commissioning	20
     5.4.3 Steady State Operations at Ft. Benning	21
     5.4.4 Emissions and Destruction Efficiency Testing	25
  5.5 Sampling Protocol	26
  5.6 Equipment Calibration and Data Quality	26
     5.6.1 Calibration of Equipment	26
     5.6.2 Quality Assurance	27
6.0 PERFORMANCE ASSESSMENT	29
  6.1 Power Production	29
  6.2 Emissions	31
  6.3 Destruction Efficiency	31
  6.4 Greenhouse Gas Reductions	31
  6.5 Economics	32

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  6.6 Operability -Availability, Reliability and Ease of Use	32
7.0 Economics	34
8.0 SCHEDULE OF ACTIVITIES	38
9.0 MANAGEMENT AND STAFFING	39
10.0 REFERENCES	41
  Appendix A: Points of Contact	44
  Appendix B: Draft Health and Safety Plan (to be modified based on Ft. Benning Requirements)	45
List of Tables
Table 1. Flex Operating States
Table 2: Performance Objectives
Table 3: Operational Timeline
Table 4. Instrument Specifications for Continuous Monitoring
Table 5. Supplementary Data to be Acquired from integral Flex Sensors
Table 6. Parasitic Loads
Table 7. Pollutants and Emissions Test Methods
Table 8. Flex Demonstration Cost Elements

List of Figures
Figure 1. Flex Schematic
Figure 2: First Division Road Landfill
Figure 3: Collection System & Flare (subsequently fenced)
Figure 4: 1st Division Road Landfill Collection System (courtesy USAGE)
Figure 5: Flex System Site Plan - Ft. Benning Installation
Figure 6: Flex System Monitoring Schematic
Figure 7: LFG Measurement Configuration Detail
Figure 8: Proposed  Schedule
Figure 9: Project Staffing
Figure B-l: Emergency Services Location
                                                in

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List of Acronyms
Acronym
ADQ
BTU
BTU/h
CARB
CO
CO2, CO2e
CT
DoD
DQO
DRE
ECAM
EPA
ESTCP
ETV
GAEPD
LFG
LMOP
MQO
NESHAP
NIST
NMOC
NOX
PM10
PM2.5
QA/QC
SUT
THC
TOC
TRS
USEPA
VOC
USAGE
scf
psi
ppm
APB
MSW
eGRID
scfm
Definition
Audit of data quality
British thermal units (energy, usually thermal or chemical)
British thermal units per hour (rate of energy transfer or use)
California Air Resource Board
Carbon Monoxide
Carbon Dioxide, Carbon Dioxide Equivalent
Current Transformer
United States Department of Defense
Data Quality Objective
Destruction Removal Efficiency
Environmental Cost Analysis Methodology
U.S. Environmental Protection Agency
U.S. Department of Defense Environmental & Security Technology Certification Program
Environmental Technology Verification program
Georgia Environmental Protection Department
Landfill Gas
Landfill Methane Outreach Program (USEPA)
Measurement Quality Objective
National Emissions Standard for Hazardous Air Pollutants
National Institute of Standards and Technology
Non-methane organic carbon
Oxides of Nitrogen
particulate matter with an aerodynamic diameter up to 10 |im
particulate matter with an aerodynamic diameter up to 2.5 |im
Quality Assurance / Quality Control
System Under Test
Total Hydrocarbons
Total Organic Carbon
Total Reduced Sulfur
Environmental Protection Agency
Volatile Organic Compound
U.S. Army Corps of Engineers
Standard Cubic Feet
Pounds per Square Inch
Parts per Million
Air Pollution Board
Municipal Solid Waste
Emissions & Generation Resource Integrated Database
Standard Cubic Feet per Minute
                                        IV

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MOA
ASERTTI
NPT
QMP
QAM
ECAM
BLCC
IRR
OMB
Memorandum of Agreement
Association of State Energy Research and Technology Transfer Institutions
National Pipe Thread
Quaity Management Plan
Quality Assurance Manager
Environmental Cost Analysis Methodology
Building Life-Cycle Cost
Internal Rate of Return
Office of Management and Budget

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Acknowledgments
This project is  funded  under the U.S. Department of Defense Environmental Security Technology
Certification Program (ESTCP), Energy & Water (formerly Sustainable Infrastructure) Program.  This
Demonstration Plan has been  developed by Southern Research  Institute  in  accordance  with the
requirements of this program and, as operator of the Greenhouse Gas Technology Center, to qualify as a
technology  verification  project  under the U.S. EPA Environmental Technology  Verification (ETV)
Program.

This plan will appear both as a Demonstration Plan under DoD ESTCP -Project 200823 and as a Test and
Quality Assurance Plan document SRI/USEPA-GHG-QAP-50 under the U.S. EPA ETV program.

We would like to acknowledge the following organizations, programs, and individuals for the valuable
contribution to this document.

US Army Corps of Engineers (USACE)

    •   Anna Butler, USACE, Savanah District, Technical Manager (project champion)
    •   Dorinda Morpeth, USACE, Environmental Program Manager, Solid Waste & Recycling (on-site
       Ft. Benning)
    •   Tannis Danley, USACE Environmental (on-site Ft. Benning)
    •   John Brendt, Chief of Environmental Division, (on-site Ft. Benning)
    •   Vernon Duck, Energy Manager, (on-site Ft. Benning)
    •   Benny Hines, Public Works Manager,  (on-site Ft. Benning)

FlexEnergy

    •   Edan Prabhu
    •   Paul Fukumoto
    •   Charlie Pattabongse
    •   Rice Berkshire
    •   Doug Hamrin
    •   Adam Robinson
                                              VI

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                       DEMONSTRATION PLAN


      Demonstration and Verification of a Turbine Power Generation System
                         Utilizing Renewable Fuel: Landfill Gas

                              ESTCP Project Number EW-200823

                                        February, 2011


1.0 INTRODUCTION	


1.1 Background

The U.S. Department of Defense (DoD) occupies over 620,000 buildings at more than 400 installations in
the U.S, spending over $2.5 billion on energy consumption annually. Reductions in energy consumption
from these facilities and utilization of renewable energy  sources  has become a primary goal of the DoD
for several reasons: (1) to reduce emissions and environmental impacts related to power production and
consumption in response to air pollution and climate change issues;  (2) to reduce costs associated with
energy consumption, resulting in additional resources aimed at the DoD primary mission; and (3)  to
improve energy security, flexibility, and independence. More recently,  these priorities have been re-
enforced through the release of Executive Order  13423, Strengthening Federal Energy,  Environmental
and Transportation Management [1].

A potential resource for the production of renewable energy on-site - a secure and efficient process - is
landfill gas from DoD owned landfills at domestic bases.  As part of this project, Southern identified and
collected data from 471 landfills operated within DoD.  Landfills produce waste gas streams containing
methane that is often vented to the atmosphere or destroyed via  a flare. In addition, various other waste
gas streams  may exist at DoD sites as  well (i.e.,  remediation systems,  industrial processes, etc.).
Destruction of these waste streams is often energy intensive, and results in significant emissions and
generation of waste heat. Alternative solutions that reduce energy consumption at these sites and reduce
the environmental impacts are desirable.

Southern has identified the FlexEnergy Powerstation™ 200 system as a technology that utilizes landfill or
other very low  quality waste fuels to provide efficient on-site power production. The system is potentially
applicable to a variety of DoD sites, including landfills, facilities with anaerobic digesters for wastewater
treatment,  painting or printing operations, VOC remediation systems,  as well as typical fossil  fuel
applications.

The FlexEnergy Powerstation™ utilizes, at its core,  a  conventional 250kW micro-turbine  of proven
design with  many years of field  operation.  The modification made  by FlexEnergy replaces the
conventional combustion chamber with a thermal oxidizer, enabling the system to operate with very low
heating value fuels.

Using this technology, the productive life  of energy recovery systems at landfills may be substantially
extended, as the quality of gas tapers off below  the  operating  threshold of  other typical technologies
utilized  in this application.  In addition, the thermal  oxidizer approach  promises a higher destruction
efficiency of Volatile Organic Compounds (VOCs) and other pollutants. The use of the oxidizer may also
allow for simpler, less rigorous gas cleaning prior to use than other conventional systems.

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1.2 Objective Of The Demonstration

The objective of this demonstration is to provide a credible, independent, third party evaluation of the
performance and  economics of the  FlexEnergy technology in  a landfill gas (LFG)  energy recovery
application. This evaluation will provide sufficient data to allow end-users,  purchasers, and others to
determine impacts of the technology and their applicability across DoD sites and other applications.

Success factors to be validated during this test include energy  production and quality, emissions and
emission reductions  compared to existing systems, economics, and operability, including reliability and
availability.

1.3 Drivers

Energy  security, environmental sustainability, and long-term savings are all drivers  for the subject
technology.

On October 5, 2009 President  Obama issued Executive Order 13514 [3] titled "Federal Leadership in
Environmental, Energy and Economic Performance".  Among other things, this Order challenges Federal
agencies to increase energy  efficiency, reduce direct and indirect greenhouse gas emissions and prevent
pollution.  Executive Order 13423, signed January 24, 2007, also directs Federal agencies to increase use
of renewable energy.  The Energy Independence  and Security Act  of 2007  also  emphasizes  the
development and use of renewable energy. The Energy Policy Act (EPAct) of 2005 seeks to promote
innovative technologies that avoid greenhouse gases, including renewable energy technologies.

The utilization of the Flex Powerstation™ using landfill gas has potential impacts in all of these areas by:

   •    Using a renewable fuel resource (landfill gas);

   •    Improving  energy  efficiency by  reducing  energy consumption  associated  with  flare  use,
       transmission losses, etc.;

   •    Reducing greenhouse  gas emissions  by producing electricity from gas  that was formerly not
       utilized and  combusted  in the flare.
2.0 TECHNOLOGY DESCRIPTION


2.1 Technology Overview

FlexEnergy has developed the Flex Powerstation™ (Flex), a unique power plant that generates electricity
from extremely low energy content gas.  The Flex uses a proprietary thermal oxidizer system in place of
the turbine's combustor to oxidize  and destroy hydrocarbons in the waste fuel stream.  The oxidizer
allows the Flex to operate using fuel gas or vapor that is below the typical requirements for combustion
by diluting methane gas to  15 BTU/scf or 1.5% methane. The Flex uses conventional, 'off-the-shelf gas
turbine/generator technology with a long history of reliable operation  (Ingersoll Rand MT250  series
microturbine).

For over ten years, FlexEnergy pursued the development of a power plant that could operate on a wide
variety of low  quality fuels. Research was supported by government grants from the Department of
Energy, the National Renewable Energy Laboratory, California Energy Council, and other agencies.  In
2002 FlexEnergy received  a U.S. patent for a "Method for Collection and Use  of Low Level Methane
Emissions".

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The original Flex was a catalytic combustor coupled with a 30 kW micro-turbine. Experience with the
catalytic Flex led to the use of a non-catalytic thermal oxidizer. The catalytic combustor life was severely
reduced by contaminants in the waste gas streams of interest. Thermal oxidizers are a proven solution to
many of the problematic gases. Redesigning the Flex for the more robust and forgiving thermal oxidizer
technology largely eliminates the need for fuel cleanup.

During normal operation, the fuel gas (or vapor) is diluted with ambient air to 15 BTU/scf and injected
into the turbine's compressor. The compressed air/fuel mixture (-60 psi) is then preheated and enters the
thermal oxidizer where it is heated further and contaminants are destroyed. Hot gas from the thermal
oxidizer powers the turbine, which turns the generator, producing electric power. Exhaust gas from the
turbine is used to preheat the air/fuel mixture entering the oxidizer.

During startup, the oxidizer must be preheated and the turbine brought to operating conditions before the
system can operate in steady state 'Flex' mode.  For this purpose, a startup system is provided consisting
of supplemental fuel, a gas compressor,  and  combustors at the oxidizer inlet and outlet. Table  1
summarizes the operating  states for the Flex and auxiliary systems  (startup  and blower skids). Figure 1
provides an overall schematic flow diagram for the Flex.

                                Table 1. Flex Operating States

Gas Turbine Speed
Generator Output
Start Skid
Blower Skid
Start Initiation
low& ramping
no output
on
off
Warm Up
ramping to full
zero to ramping output
on
off
Transition
full
ramping to full output
on ramping to off
off ramping to on
Flex Mode
full
full output
off
on
Continuous Operation
full
full output
off
on
A prototype Flex oxidizer system was assembled in October,  2008, with the  first successful  system
operation on 1.5% methane accomplished after 10 months of development testing. The prototype system
re-packaging into the pilot field system was started in November, 2009. The pilot  system was delivered to
Lamb Canyon Landfill in Beaumont, California, in late May, 2010, and was successfully operated on
landfill gas in June, 2010. As of September, 2010, the Flex had accumulated over 480 hours of operation
on landfill gas. The  pilot plant  has also  demonstrated the ability of the oxidizer-based system to continue
operation  during intermittent  fuel  supply interruptions. The pilot plant operation continues at Lamb
Canyon Landfill for engineering  control development and integration with the day to day operation at a
landfill.

The Flex Powerstation™  is capable of utilizing other waste streams as the fuel input, such as paint booth
or other VOC-laden industrial process exhausts, off-spec  fuels,  waste solvents,  and other low  BTU
wastes.  Demonstration of the operation of the turbine  on other waste  streams will be addressed in a
second Flex Powerstation™ installation (to be determined).  The  present demonstration addresses  landfill
gas applications only.
    ESTCP Demonstration Plan
February, 2011

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                    -500F
                                                                            (1) Oxidizes Fuel
        Power
       to Grid
     FUEL GAS
                     AIR
           (2) Mixes Fuel & Air prior to Compression
                                  Figure 1. Flex Schematic

2.2 Advantages and Limitations of the Technology

The chief advantage of the Flex technology is the ability to utilize very low BTU fuel sources to provide
electrical energy and  heat.   Since these low value fuel sources  are  often waste  streams, a related
advantage is reducing costs associated with treatment of these wastes and realizing offsets of energy and
emissions associated with waste treatment.  Because of the ability to utilize low-BTU gas, the energy
generating potential of a landfill can be extended well beyond the period when methane concentrations
are high enough to support combustion (typically limited to approximately 350 BTU/scf). This process
also eliminated the need for a separate fuel compressor, as the blended low-BTU fuel-air mixture can be
compressed by the turbine's integrated compressor.

Thermal oxidation is an effective means of destroying non-methane organic carbon compounds (NMOC)
and other organic pollutants. As a result, Flex emissions are expected to be as good as or lower than
alternate  LFG destruction/utilization technologies.  In addition, the oxidizer prevents NOX formation, a
significant advantage, while fully destroying CO and VOCs.

For LFG applications, the Flex does not require a complex gas cleanup system - often a significant issue,
as particulates formed from siloxane  oxidation  are trapped within the oxidizer and  other potential
pollutants are oxidized in the system.
    ESTCP Demonstration Plan
February, 2011

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The 250kW Flex system should have wide applicability, as a single unit can be used with fuel sources as
small as 3 million BTU/hr and multiple units can utilize larger sources. Since the unit is fuel flexible and
adapts to fuel concentration, it can also be utilized with somewhat variable fuel sources.

The chief limitation of the  Flex system is that it is as yet unproven in its many potential applications
beyond  energy recovery  from  landfill  gas, and has  only  been  shown in limited demonstration.
Achievement of all power production goals, emission goals, and equipment reliability, as well as system
economics, has not been fully demonstrated beyond the current pilot facility.  In addition, in the current
Flex design, the fuel source is diluted with air to 15 BTU/scf heat content and injected directly into the
turbine's  compressor.   Some  potential  fuel  sources  may  require  gas cleaning,  cooling,  or  other
pretreatment to avoid excessive compressor maintenance.
3.0 PERFORMANCE OBJECTIVES	

The performance objectives for the demonstration system relate to the environmental, economic and
operational impacts of the Flex system compared with baseline conditions at the test site. The baseline
consists of operation of the host landfill with the existing landfill gas extraction and open flare destruction
system.

The system under test (SUT) includes the Flex system (oxidizer and turbine) and associated support
equipment (i.e., LFG blower and system startup components) and excludes the existing LFG extraction
and open flare destruction system.

Data requirements and success criteria for the primary objectives  for this demonstration are  given in
Table 2 with details provided in the remainder of this section.

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                                 Table 2: Performance Objectives
      Objective
        Metric
   Data Requirements
       Success Criteria
3.1 Energy: Verify
power production &
quality.
Net real power delivered
(kWh); frequency (Hz),
power factor (%); total
harmonic distortion
(THD)
Long term, continuous
monitoring of generator
power output and parasitic
loads. Short term
verification of power
quality parameters.
Nominal 200kW gross
continuous (1750 MWh/yr) less
de-rating depending on ambient
conditions (to be established).
Power quality meets utility
inter-connection requirements.
3.2 Emissions: Verify
emissions meet
regulatory
requirements and are
lower than best
alternate LFG
emissions control
technology.
 Ib/hr, Ib/MWh or ppm
emitted
Emissions measurements of
CO2, NOX, SO2, CO, TRS,
PM (2.5 and 10), THC and
methane (thus NMOC).
Emissions meet or exceed
CARB 2013 requirements for
distributed generation and host
site air permit requirements.
Emissions are lower than EPA
AP-42 typical values for best
alternate LFG control
technology (boiler/steam
turbine).	
3.3 Emissions: Verify
NMOC destruction
efficiency
Percent destruction
efficiency for NMOC.
Field emissions
measurements at
recuperator exhaust and
analysis of LFG samples at
Flex inlet.
NMOC Destruction efficiency
exceeds 98 percent and meets
or exceeds the EPA AP42
typical destruction efficiency
for Boiler/Steam Turbine
(98.6%).
3.4 Emissions: Verify
greenhouse gas
emissions reductions.
Metric tons CO2e/yr
reduction relative to site
specific baseline
conditions.
Power generation offsets
based on local utility
emission factors.
Greater than 800 metric tons
CO2e avoided emissions due to
power generation (above
baseline).  Greater than 8000
metric tons CO2e reduction due
to destruction of CH4. Greater
than 10% increase in GHG
reduction compared to flare
only.
3.5 Assess economic
performance
Simple payback (years),
NPV($)
Capital and operating/
maintenance costs.
Revenue based on electric
energy production offset,
including renewable power
cost increment.
Simple payback < 5 years;
Positive NPV.
3.6 Determine system
availability/reliability
and operating impacts.
Percent
availability/reliability,
plus descriptive
narrative of installation,
operation, maintenance
requirements.
Daily log of normal
operations, scheduled and
unscheduled downtime,
problems and
causes/responses.
Documentation of system
installation requirements
(permits and approvals,
etc.) and operational
requirements (staffing).
Availability exceeds 95%.
Reliability exceeds 97%.
Operability is acceptable.
    ESTCP Demonstration Plan
                                                          February, 2011

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3.1 Power Production and Quality

Demonstrating Flex power production is a key component of this demonstration in order to verify that the
Flex meets target power output specifications and because project revenues and GHG reductions depend
largely  on the energy recovered.   Power quality must be verified  to  meet utility  interconnection
requirements.

The Flex Powerstation's™ electrical efficiency and an estimate  of potential heat recovery will also be
determined as part of this demonstration. These determinations are not considered formal performance
objectives and do not have specific success criteria but are included for informational purposes.  The Flex
system to be demonstrated here will not utilize heat recovery.

3.1.1  Metric and Data Requirements

The power production metric is net real power delivered (kWh). Net power output is gross output less
continuous (blower and controls) and intermittent (startup) parasitic loads. Net power production will be
monitored continuously throughout the one year demonstration period to allow for determination of the
total integrated power output over the full year of demonstrated operation and provide for determination
of seasonal de-rating factors.

Gross and net power output will be monitored by separately metering gross power output and parasitic
loads.  All parasitic loads will be aggregated together and measured at a single bus. Bidirectional power
will also be monitored at the utility interconnect, a meter provided by Flex and the local utility,  Flint
Energies. The monitored gross power output less net monitored power should match the bidirectional
meter data at the interconnection.

The power quality metrics are voltage  (V), current (A), frequency  (Hz),  power factor (%),  and  total
harmonic distortion (THD). Power quality will be verified at the point of interconnection during system
commissioning.

The data requirements for electrical efficiency  include net power output  and heat input.  Heat input
(BTU/hr) will be determined from LFG flow and methane concentration measurements at the Flex inlet.
These parameters will be monitored  continuously during the one year demonstration period.  Electrical
efficiency is  expected to be approximately 22% or 15000 BTU/kWh  (based on turbine  manufacturer
specifications).

To estimate heat recovery potential, exhaust gas temperature and  mass flow will be measured during the
intensive monitoring period.   The potential heat recovery estimate will be  based on  characteristic
specifications for heat recovery systems frequently installed with micro-turbines.  Preliminary  estimates
show the heat recovery potential to be over 1 million BTU/hr.

3.1.2  Success Criteria

The target power output for the Flex 250 unit is 200kW (maximum 210 kW) at 60 degrees F and allowing
for  ambient condition dependent de-rating.   Output will decrease at higher  temperatures  or lower
pressures  and increase at lower temperatures  due to the  effect of inlet gas temperature on turbine
performance.  The annual average ambient temperature for the Ft.  Benning demonstration site  is 64
degrees F [19].

The power  quality must meet or exceed the  requirements  of the local utility  (Flint  Energy) for
interconnection.  The power output specifications for the Flex turbine are  3 phase, 480VAC,  60 Hz, 4
wire wye, 300 amps nominal (250 kW).  As this type  of turbine has been installed in many other utility
interconnection applications, the output will meet Flint Energy's requirements without modification.

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3.2 Emissions

Low air pollutant emissions (primarily NOX, CO and NMOC) are a key performance claim for the Flex
technology, and verification of low emissions is, therefore, a key component of the demonstration. The
overall goal is to demonstrate that Flex emissions are likely to meet the potentially applicable emission
standards, and, particularly, any emissions limits that may be set for operations at the Ft. Benning test
site.

Air permitting for the Ft. Benning Flex demonstration will be handled as an 'off-permit request' as the
GA EPD Air Pollution Branch (APB) does not consider the Flex to be  a significant source and  is not
subject to NSPS requirements. Documents have been submitted to the APB describing the technology
and Ft.  Benning installation,  estimating potential to  emit and documenting compliance testing at the
Lamb Canyon demonstration site.

3.2.1 Metric and Data Requirements

Emissions standards or limits are stated in various units/activity factors in regulations; for example, ppm,
Ib/hr, Ib/MWhr, Ib/MMscf LFG, Ib/MMscf methane.  During the emissions test,  sufficient data will be
collected to report emissions in any of these terms.

While it is anticipated that emissions limits will be imposed only for NOX, CO and NMOC,  other
pollutants are of interest, and Southern plans to  conduct emissions testing for CO2, NOX, SO2,  CO, TRS,
PM (2.5 and 10), THC and methane (thus NMOC).

The  emissions test will take place during the intensive monitoring period after the Flex has been
operational for at least 1000 hours. The emissions test will be treated as a compliance test requiring three
sampling/analysis runs of one hour each according to EPA reference methods (see section 5 for more
detailed information).

3.2.2 Success Criteria

As the Flex is a unique modification of conventional gas turbine technology, it is not clear whether
existing standards for gas turbines may be applied by local permitting authorities. Southern conducted a
review of emissions standards that may be applicable to Flex systems installed in the United States. This
included:

   •    California Air Resources Board (CARB) standards for distributed generation [1],

   •    South Coast Air Quality Management District (SCAQMD) permit for the ongoing  lOOkW Flex
       demonstration project  [2]

   •    Typical SCAQMD permitting levels (as reported by Flex)

   •    Georgia Environmental Protection Division standards for gas turbines [3]

   •    US EPA New Source Performance Standards for gas turbines utilizing landfill gas [4]

   •    EPA AP-42 typical emissions  for best LFG control technology (2008 draft update) [5]

Emissions limits from these standards were converted to a common Ib/hr basis for the Flex 200kW unit
(using nominal exhaust flow and fuel efficiency) and compared.  The CARB 2013 standards were  found
to be the  most stringent.  The CARB standards apply to any distributed  generation unit operated in
California. For the purpose of this demonstration, the CARB standards are used as the success criteria for
emissions. For the Flex 200kW unit, the CARB  2013 standards are the following:

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    •   NOx = 0.0141b/hr,

    •   CO = 0.02 Ib/hr,

    •   NMOC = 0.004 Ib/hr.

Meeting the CARB standards will also meet EPA AP-42 typical emissions for best alternate control
technologies (enclosed flare or boiler/steam turbine, depending on pollutant). In addition, AP-42 gives
typical emission factors  for total PM for LFG emissions control devices.  For the Flex 200 unit, this
amounts to an emission limit of 0.009 Ib/hr PM to meet AP-42's best alternate LFG control technology
(boiler/steam turbine).

The NSPS are the only emissions standards reviewed that provide an emission limit for SO2. The NSPS
standard is  150 ppm (or <8000 ppm total fuel sulfur content).  For the Flex 200kW unit, this amounts to
an emissions limit of about 4 Ib/hr.

3.3  Destruction Efficiency

EPA regulations (NSPS  and NESHAP)  require a 98 percent NMOC destruction efficiency for landfills
over a certain capacity or that may emit over a certain quantity of NMOC.  Therefore, verifying the
NMOC destruction efficiency of the Flex is an important performance objective for this demonstration.

3.3.1 Metric and Data Requirements

Destruction and removal efficiency (DRE) is determined by comparing the mass flow rate of a pollutant
at the inlet and outlet of a control device. The DRE is given by the difference between the inlet and outlet
mass flows divided by the inlet mass flow  and multiplied by 100 to yield a percentage.   During the
intensive monitoring period, NMOC mass flows will be determined at the Flex inlet at the same time that
NMOC emissions are measured at the Flex exhaust.  Three, one-hour determinations will be made.

3.3.2 Success Criteria

The  1996 EPA Standards of Performance for New Stationary Sources (NSPS) and Guidelines for Control
of Existing Sources, as  well  as the 2003 National Emission Standards  for Hazardous Air Pollutants
(NESHAP), require  "large"  municipal solid waste  (MSW) landfills to collect LFG and combust it to
reduce NMOC by 98 percent (or to an outlet concentration of 20 parts per million by volume). A "large"
landfill is defined as having a design capacity of at least 2.5 million  metric tons and 2.5 million cubic
meters and a  calculated or measured  uncontrolled NMOC emission rate of at least 50 metric tons
(megagrams) per year.  [6]

The  demonstration site landfill has a capacity of roughly  1 million tons, so this landfill is exempt from
these standards. However, for the purpose of this demonstration, 98 percent NMOC destruction efficiency
is taken as minimum success criteria for the Flex.

EPA AP-42 typical destruction efficiency for an enclosed  flare is 97.7% and  is 98.6% for a boiler/steam
turbine. Therefore, the Flex should also meet or exceed 98.6 percent NMOC DRE.

As part of the test, measurements will also be made that will allow determination of the DRE for methane.
The DRE for methane should exceed 99% [7].

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3.4 Greenhouse Gas Reductions

One of the key drivers for ESTCP Sustainable Infrastructure Energy & Water Projects is to demonstrate
GHG reductions.

The primary GHG reduction for the Flex demonstration is the result of electric utility emissions offset by
the power produced by the Flex.  There are some other potential GHG reductions attributable to the Flex
(see below).  These reductions will be considered in the Flex performance assessment. However, the
quantitative success criterion is based on Flex power production alone.

The Flex also destroys methane, and this is a much larger  GHG reduction. However,  methane is also
destroyed by the existing candlestick flare at the demonstration site, so any incremental reduction would
be due to increased methane destruction efficiency of the Flex over the Flare.  This incremental reduction
cannot be  determined quantitatively, however, since the methane destruction efficiency  of a candlestick
flare cannot be readily measured.  In  any case, this is likely to be a very small increment.  In EPA's
LMOP Landfill Gas to Energy calculator, it is assumed that the methane destruction efficiency for all
LFG to energy devices is  100 percent. [8].

Another potential source of GHG reductions or increases attributable to  the Flex and compared to the
baseline is a reduction in supplementary fuel usage for the  existing flare. The flare is supplied with a
propane fuel source; however, the propane is used only to maintain the pilot flame and fuel use over time
has been insignificant (personal communication from Fred Portofe of J2 engineering, Ft. Benning's flare
operation contractor). There is not expected to be any significant change in propane use with  the Flex
installed.

Finally, there may  be net (over baseline) GHG reductions  attributable to the Flex resulting from the
ability of the Flex to utilize low methane LFG in future years after the LFG heat content falls below the
minimum required for flare operation (200 BTU/hr) [9] [40 CFR60.18 and 63.11] or after LFG extraction
and destruction is no longer required to mitigate  offsite migration of LFG.  Such reductions, however,
cannot be  quantified with any precision, and are beyond the  scope of the one year demonstration period,
so will not be accounted for in this demonstration.

3.4.1 Metric and Data Requirements

The GHG reduction metric is metric tons CO2e reduction per year based on avoided emissions for utility
electric power generation for the State of Georgia. Emission factors for carbon dioxide, methane, and
nitrous oxide from the most recent eGRID database [10] will be weighted by current EPA accepted global
warming potentials (e.g., Table ES-1 in EPA's 2010 GHG Inventory)  [11]  to arrive at the total combined
CO2e emission factor in metric tons/MWh. Currently, this factor is 0.64 metric tons/MWh.

In addition to the emission factors, the required data are the same net power production measurements for
the power production objective (section 3.1).

3.4.2 Success Criteria

Based on current  emission factors, the Flex  is expected to avoid emissions of 800 metric tons CO2e per
year due to power generation.

More than 8000 metric tons CO2e emissions are expected to  be reduced directly by the Flex through the
destruction of methane.  The destruction of methane is not a net reduction  over baseline conditions, since
the existing flare also destroys methane.

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Accounting for the expected proportion of LFG flow to Flex and the Flare, the additional avoided GHG
reductions provided by the Flex amount to about a 10 percent GHG reduction compared to the baseline
flare.

These calculations use formulae  adapted from EPA's LMOP  GHG emissions reductions calculator [8]
adjusted for estimated capacity factors specific to Flex and site specific emission factors.

3.5 Economics

To be economically viable, the value of the power produced by the Flex must offset the capital, operating
and maintenance costs of the Flex over a reasonable period of time.

3.5.1  Metric and Data Requirements

The metrics  used to assess Flex economic  performance will  be standard indicators  of  economic
performance including the simple payback period and net present value. These indicators are determined
from the initial capital and incremental operating  and maintenance costs for the SUT, offset by the value
of the electric power produced over time with proper accounting for the time value of money.

Capital and operating/maintenance costs will be compiled based on actual  and  projected expenditures
using  appropriate discount rates as detailed in Section 7 of this plan.

The cost of installing and  operating the existing gas collection and  flare  system at the Ft. Benning
demonstration site will not be included in this analysis as these systems are part of the baseline in this
case.  However,  for sites without a gas collection and flare system, costs for these components may be
included.  While not part of this demonstration,  such costs will be estimated in planned guidance and
outreach materials.

3.5.2  Success Criteria

The simple payback period should be less than 5 years with net present value (NPV) greater than zero.
Because Flex is  a developmental technology, the payback period for the Ft. Benning installation may
exceed 5 years. The payback period for a more typical,  future  commercial installation will be estimated
and presented in  the final report based on projected capital and annual operating costs.

3.6 Operability

In order to be successful, the Flex system must provide sufficient  availability, reliability and ease of use
so that the economic value of power production is realized and no undue burden is placed on operations
staff.

3.6.1  Metric and Data Requirements

Availability is a quantitative metric that is given  as the  percentage  of time that the system is either
operating or capable of operation if down for unrelated reasons (such as  power failure or failure of the
LFG collection system). The data requirements are power production data logged as described in section
3.1 and operational logs providing details of the causes and circumstances for each period when the Flex
is not  producing power at expected levels.

Reliability is both a quantitative and qualitative metric that assesses the robustness of the system in terms
of likelihood  of  failure or operational problems,  the consequences of such problems, and the ability to
recover.  Reliability will be assessed quantitatively in accordance with ANSI Standard 762 which uses a

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specific categorization of operating and downtime hours.  Reliability will also be assessed qualitatively
based on the operating experience of project participants (including Southern Research, Flex and local
operators). Operating experience will be documented with narrative descriptions from Southern Research
and Flex and interviews with operating staff at the conclusion of the project.

Ease of use is a qualitative metric that will be based on operating experience during the demonstration
period as documented by narratives and interviews with operators and project participants during and at
the conclusion of the project.  The ease of use  assessment will encompass the entire design and
installation process, including permitting and other approval requirements. The acceptability of a newly
introduced technology is partly dependent on the subjective experience of operations and maintenance
personnel.  If these personnel require highly specialized training, or intensive permitting and  approval
processes, the  cost of installation, training,  and operations increases. Difficulty with system operation can
also  reduce availability,  since when the  system fails it is less likely that  someone with the correct
expertise will be immediately available.

Details for calculating availability  and reliability and the required content of operations logs, narratives
and interviews are given in section  6.6.

3.6.2 Success Criteria

The Flex system is designed for unattended 24/7 operation and is expected to be available at least 95
percent of the time and achieve a quantitative reliability rating of 97 percent or greater. The system should
receive a positive qualitative assessment of overall reliability and ease of use.
4.0 FACILITY/SITE DESCRIPTION	

The Flex demonstration will take place at the 1st Division Road landfill at Fort Benning, Georgia.

4.1 Facility/Site Selection

Southern Research previously prepared an inventory of all Department of Defense (DoD)  established
landfills with information suitable for assessing the usable energy production potential for each site as
well as factors that may influence commercial and technical decision-making with respect to recovery of
that energy.

As  part of this  effort, site  selection criteria were  developed and candidate sites were  identified  and
evaluated for the Flex demonstration.

Because  extended productive  life of landfill gas power is  one of the claims of the technology, it is
desirable to demonstrate on a mature, closed landfill.  To meet program funding requirements, the  site
should have an existing gas collection/flare system that is in a good state of repair and may be operated
throughout the planned demonstration program period. The gas production level should be expected to be
able to support at least one 200 kW FlexEnergy turbine (>3 million BTU/h average rate) for at least five
years.  Electrical interconnection should be reasonably accessible to the location of the gas collection
system and location of the Flex Powerstation™ equipment. The site  should be representative of typical
target application landfills at DoD bases in terms of age and size.

The 1st Division Road landfill at Ft. Benning meets all of these criteria. Fort Benning indicated immediate
interest in  participation when first contacted in 2007 and has consistently backed up this interest by
providing supporting data and documentation promptly as and when requested.  On-site meetings have
taken place with the following:

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    •  Anna Butler, USAGE, Savanah District, Technical Manager (project champion)
    •  Dorinda Morpeth, USAGE, Environmental Program Manager, Solid Waste & Recycling (on-site
       Ft. Benning)
    •  Tannis Danley, USAGE Environmental (on-site Ft. Benning)
    •  John Brendt, Chief of Environmental Division, Ft. Benning
    •  Vernon Duck, Energy Manager, Ft. Benning
    •  Benny Hines, Public Works Manager, Ft. Benning

All have indicated a high degree of support for the project.

4.2 Facility/Site Location, Operations and Conditions

The 1st Division Road Landfill is located on Ft. Benning grounds near the intersection of 1st Division
Road and US highway 27/280 (see Figure 2).  The landfill contains approximately 48 acres of fill material
at an average depth of 30 feet (approximately 2.3 million cu yd).  The landfill is unlined, and capped with
a geosynthetic clay liner with at least 24 inches of drainage material and six inches of vegetative cover.
Based on the waste acceptance rate and the volume of the  landfilled waste, the landfill is estimated to
contain approximately 1 million tons of total waste.

The landfill  accepted municipal solid waste and construction/demolition debris for more than 12 years
starting in 1985 until closure  in 1998.  The waste acceptance rate was approximately 175 tons per day. In
1993, three methane and ten groundwater monitoring wells were installed along the western property
boundary. Methane levels exceeding the lower explosive limit were detected in the wells. In 1996, seven
additional methane and eight  additional groundwater monitoring wells were installed.  In 1998, 39 passive
landfill gas vent wells were  installed in compliance with the Georgia DNR approved closure plan.  In
1999, three additional methane monitoring wells were installed off-site to the west of the landfill due to
elevated methane detected at the landfill boundary.

In 2003, landfill gas generation rates were quantified based on vent performance tests. Based on this, the
landfill was estimated to be capable of producing 700 scfm of landfill gas at 40 to 50  percent methane
from 2005 through 2020-2025. Up  to 40 percent of the total landfill gas generated was estimated to be
escaping through westward migrating gas.  [12]

In 2004,  18  of the  39 passive vent wells were converted to an active extraction system and an open
'candlestick' flare system was installed to safely destroy the collected gas (figure 3).  This measure was
intended to mitigate problems with westward migration of the gas offsite.

In 2008,  the gas extraction  system was overhauled due to subsidence of the  landfill material having
caused the underground piping of the gas collection system to become ineffective. Improvements were
made to enhance landfill cover and drainage and the gas collection headers were installed on  adjustable
supports above ground.

Due to continued problems with offsite methane migration, the  gas collection system has been recently
expanded to 31 wells (completed as of October 2010) and an additional blower installed to increase  gas
extraction. Figure 4 shows the complete gas collection system as modified in September 2010. Equipment
is currently  being  installed  to measure  the  aggregate landfill  gas  flow rate  from  the expanded  gas
collection system.

Monthly  wellhead monitoring  data from June '08 through January  '11  show aggregate landfill  gas
production rates averaging 190 scfm (range 2 to 635 scfm) at an average methane content of 42 percent
(range 26 to  58 percent) - or  an average of 4.8 MMBTU/hr.  This value is thought to be an underestimate
of the production rate since wellhead flow rates of zero were frequently recorded where it is  likely that
there was some flow  at these wellheads that was not detected  by the wellhead monitoring  instrument

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(LandTec GEM2000). Monitoring was conducted only at the wellheads and there has historically been no
monitoring of the total gas extraction/flaring rate.

Since October 2010, with the expanded extraction system completed, monthly measurements of methane
concentration and LFG flow rate have been conducted at the flare giving a better indication of the landfill
gas production rate. In addition, since late January 2011, flow data have been obtained at the flare on a
daily basis and methane concentration data obtained approximately weekly.  Over this period, the heat
content of the LFG  has ranged from 6.5 to 8  MMBTU/hr. Over this  period, methane  and CO2
concentration  readings at the flare have ranged from only  about 25 to 30 percent (each).   This may
indicate that ambient air is being drawn into the landfill or that there are leaks in the extraction system.
Work is ongoing to balance the extraction system and troubleshoot any problems.

The Flex Powerstation™ will require  about 3-4 MMBTU/hr to operate (at nominal conditions). There
appears to  be sufficient gas production to  operate the Flex 250 unit. The existing flare will continue
operation during the Flex demonstration and will consume all excess gas. The flare requires a minimum
200 BTU fuel heat content to operate within regulatory requirements.

The electric power supplier is Flint Energies on base, with power supplied to the base via Georgia Power,
which has two entry points on the base.  All sub-metering within the base by Flint Energies is for the
purpose of allocating operational costs within Fort Benning. The power generated by the Flex
Powerstation™ will solely offset on-base consumption and no commercial export agreement with the
utility will be required. The point of interconnection is within approximately 100 yards of the present
flare and head of the collection system.  There is space adjacent to the existing pad suitable to support an
additional pad for the FlexEnergy system. Electrical interconnection with the grid will be performed with
Flint Energies. Flint operates the electric power distribution system on the base. Flint Energies  will be
contracted by Flex Energy to perform the interconnection work.

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                      Figure 2: First Division Road Landfill
            Figure 3: Collection System & Flare (subsequently fenced)
ESTCP Demonstration Plan
15
February, 2011

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       -.^,       ,             ,
          Figure 4: 1st Division Road Landfill Collection System (courtesy USAGE)

4.3 Site-Related Permits and Regulations

Several permit modifications and internal approvals are required in order to commence construction and
installation of the Flex Powerstation™ at the Ft. Benning  site.  Permits and approvals include the
following:

•   Site plan drawings have been submitted to the Georgia EPD Solid  Waste Department to obtain a
    minor modification to the landfill permit to allow locating the Flex equipment approximately 25 feet
    south and east of the existing flare enclosure within a fenced area of 39 X 56.5 feet.

•   A Record of Environmental Consideration (Form 144) has been prepared by Dorinda Morpeth and
    submitted for internal review to obtain necessary approvals from Ft.  Benning environmental and
    public works departments to begin construction.

•   Southern Research has confirmed that there are no ESTCP engineering review/approval requirements
    before construction may commence.

•   The GA EPD Air Permit Engineer has indicated that the air permit modification can be handled as an
    off-permit request, as the planned turbine installation is considered an insignificant source and NSPS
    does not apply.  Information on potential  emissions and other aspects of the project has been
    submitted to the GA EPD for review.
    E5TCP Demonstration Plan
                                          :
February, 2011

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•   A  Memorandum of Agreement  (MOA) has  been prepared and  submitted  for  approval by Ft.
    Benning's Energy Manager and Garrison Commander. The MOA provides a basic description of the
    project, funding, duration, and outlines the responsibilities of each party involved.

•   A hazard assessment and site health and safety plan will be prepared and presented to the Ft. Benning
    Energy Manager for approval.

•   An electrical interconnection agreement will be established between Ft. Benning and Flint Energies,
    with all information submitted in October, 2010, and a draft agreement under review.

Southern has determined that there are  no  additional permit or regulatory requirements necessary  to
construct and operate the Flex system at Ft. Benning.
5.0 TEST DESIGN

The demonstration test is designed to provide data as required to satisfy project objectives as stated in
Section 3, and provide additional information as needed to ensure the quality and representativeness of
these data.

As this is a distributed generation project with combined heat/power applicability and is supported by
EPA's Environmental Technology Verification (ETV) program, the ETV Generic Verification Protocol
for Distributed Generation and Combined Heat and Power Field Testing [13] applies. All testing and data
analysis methods and QA/QC requirements in this demonstration plan conform to the Generic Protocol.

5.1 Conceptual Test Design

At a minimum, all that is required to demonstrate Flex performance objectives is monitoring the net
power production, conducting an emissions test, and compiling and analyzing economic and operational
data. In addition to these basic requirements, the following additional supporting determinations will be
made:

    •    The heat input to the system will be measured so that system efficiency can be determined.

    •    Ambient conditions will be monitored in order to determine variation in power output and system
        efficiency with varying temperature, humidity and barometric pressure.

    •    Selected Flex parameters (oxidizer inlet/outlet temperatures, LFG feed rate) will be monitored as
        an indication of overall system 'health' and operational status  (e.g., normal operations). Exhaust
        temperature will be monitored in order to support an estimate of the heat recovery potential of the
        system (the system to be installed at Ft. Benning is not equipped for heat recovery).

    •    Landfill gas extraction system health and gas production will be monitored via monthly wellhead
        checks and flow and methane concentration of the LFG delivered to the flare.

5.2 Baseline Characterization

The baseline system  for this demonstration is the existing LFG extraction system and open candlestick
flare.   The overall LFG extraction rate  and gas quality are inconsequential to  the objectives of this
demonstration  so  long as sufficient methane is produced to operate the Flex.  Excess  LFG will be
consumed by the flare. The majority of GHG reductions attributable to the Flex result from utility offsets
due to the power produced.  Thus, the existing 'baseline'  system plays no significant role in determining

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performance objective results for this demonstration apart from the estimated cost of installing a gas
extraction system and flare if it does not already exist at a given site.

5.3 Design and Layout of Technology Components

Figure 5 is a site plan of the layout of the Flex system components in relation to the existing flare pad
located immediately south of the landfilled  area.  The function of each of these components has been
described in section 2 above.

Figure 6 is a schematic diagram of the Flex system and the existing LFG collection/flare system showing
the location of each measurement to be made in support of quantitative determination of performance
objectives.
                                       ~"PROFANE__~ 1 _ _ _ _
                                                                      7
                                             Hex System
                            Startup Skid
                           Electrical
                           Panels^ -
                 Figure 5: Flex System Site Plan — Ft. Benning Installation
    ESTCP Demonstration Plan
18
February, 2011

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LFG From Original
 Collection System
   LFG From 2010
 Collection System

                                     O ID
                                     I o
                                     -fc. Z

                                    -V
O                                         Existing
                                         Flare
                                                SYSTEM UNDER TEST (SUT)
    Ambient
  Temperature
    Pressure
Relative Humidity  jeiT1D	
              kW (to grid)
                               Emissions
                                                              kW (parasitic)
           l>l    I       l<
          g- 
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                                 Table 3: Operational Timeline
Date
September 20 10
October/November
2010
November 2010
January /February
2011
February/March 20 11
April 20 11
July/August 20 11
April 20 12
Operational Phase
IR Turbine installed and commissioned at Alturdyne for
Oxidizer delivered and integrated with IR turbine at
integrated acceptance testing.
acceptance testing.
Alturdyne. Begin fully
Groundbreaking at First Division Road landfill. Site preparation including
concrete pads, electrical service, piping etc.
Delivery and assembly of complete Flex system at First
Division Road Landfill.
System commissioning and shakedown.
Begin Flex operations at First Division Road. Start
period.
of one year monitoring
Emissions testing (after 1000 hours operation).
End of one year monitoring period. System ownership and operation assumed
by Ft. Benning.
5.4.1 Acceptance Test

Flex Energy is assembling a system identical to the system to be installed at Ft. Benning at a test facility
at Alturdyne  in El Cajon, California. The purpose of the test system is to finalize controls integration
with the IR 250 turbine and to conduct performance testing on the full scale oxidizer/turbine unit.  This
testing will take place concurrently with site preparation  and construction activities at the Ft. Benning
demonstration site.  The overall goal of the test is to achieve 200 kW output using dilute natural gas and
to confirm emissions  meet CARB  DG 2013  standards.   The  testing  will also verify that operating
conditions are within expected ranges (e.g., heat input, temps, flows, pressures), and that controls function
within specifications, including  response to subsystem failure (e.g., power outage, fuel supply outage)
and response to changes in fuel gas composition or flow.  This test system will then be available for
installation at the second ESTCP demonstration site (to be determined) while matching components have
been delivered to Ft. Benning for installation. Flex Energy will prepare a report of acceptance test results
and Southern will review the report and maintain a copy in project files.

5.4.2 Commissioning

After the final system design is complete but before commissioning may begin, Southern and Flex Energy
will conduct a hazard and operability review (HazOp) to identify any and all potential hazards associated
with Flex operation, determine the likely frequency and consequences of each hazard, and assess the
    ESTCP Demonstration Plan
20
February, 2011

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severity of those consequences. Likely hazards associated with significant potential for injury or property
damage property must be mitigated before operations may begin.

Installation and commissioning of the Ft. Benning system will take place during the first few months of
2011.  Flex system components will be  commissioned and tested individually and as a fully integrated
system.  Southern will  prepare a narrative  description of commissioning activities  documenting any
problems encountered and corrective actions taken.

During commissioning, values of steady state operating parameters (such as oxidizer temperatures) will
be determined so that steady state conditions are well defined for demonstration analyses.

5.4.3 Steady State Operations at Ft. Benning

Full operation of the Flex system is expected to begin by April, 2011, the formal  start of the one year
demonstration period. During this period, continuous monitoring of gross and net power output will be
conducted, along with monitoring of heat input (LFG flow and methane concentration delivered to the
Flex), Flex system  'health' parameters, landfill gas extraction system parameters, and ambient conditions,
as shown in Figure 6.

Propane consumed for Flex system startup(s) will also be  recorded.  The propane startup system will be
equipped with a calibrated orifice flow element and differential pressure transmitter to monitor startup
fuel flow rate and totalized usage.  Propane fuel deliveries  and a log of site glass readings on the propane
storage tank will also be  recorded to confirm startup fuel usage.

All monitoring instruments will be connected to a data acquisition and storage system with remote access
capability. Table 4  is a list of monitoring measurements, instruments and measurement parameters.

On the same data acquisition system, Southern will also acquire data from a number of sensors integral to
the Flex Powerstation™ control system.  These data will be used as indicators of system status and will
aid screening of results so that steady state operation is accurately represented in the  data analyses.  These
parameters are listed in Table  5.

Finally, during the  steady  state  monitoring  period, Southern  will  also  obtain  flow and  methane
concentration data  for the flare feed, as well as monthly well head data for the LFG extraction system.
These  monthly data consist  of measurements at each wellhead of LFG flow  and  concentrations  of
methane, carbon dioxide and oxygen, as well as concentration at the flare inlet using a portable LandTec
GEM2000 landfill  gas meter.  The LFG  flow to the flare will be measured continuously downstream of
the Flex takeoff, indicating net flow to the flare when the Flex is operating. These data will be used to
monitor the status of the  LFG  extraction system and characterize the LFG supply.  The wellhead data will
be obtained monthly from USAGE via their contractor, J2 Engineering.

Parasitic electrical  loads are loads required for Flex operation that net against the gross power output.
The wiring for the  Flex system is configured  such so all parasitic loads will be measured together from a
single 3-phase 480V 4-wire Wye bus with a single power meter.  Table 6 lists the parasitic loads and the
associated nominal and  max  current for each load. The  gross generator output from the Flex will be
measured by a  separate  power meter.  A bi-directional power meter will also be installed at the utility
interconnect. The Flex system will record data from this meter.

The LFG feed gas  flow and methane concentration  to the  Flex will be measured on the 4 inch line from
the Flex supply blower to the compressor air inlet plenum (see Figure 5 above). These instruments,  along
with the DRE sample  port (see section 5.4.4) will be located along a spool piece provided with a bypass
so that the  instruments may be serviced without taking the Flex  offline.   To  ensure reliable flow
measurements, the  flow element will be located 10 diameters (40 inches) downstream and 5 diameters (20
inches) upstream from any obstruction to flow, although the area-averaging type flow element that will be

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used requires only a minimum of two diameters straight run of pipe upstream. The additional straight run
is planned as a precaution should an alternate flow measurement device become necessary.  The LFG
feed gas spool piece configuration is illustrated in Figure 7 below.    The differential pressure transducer
must be mounted as close as possible to the flow element with the impulse lines arranged so that any
condensation will drain away from the transducer.

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Measurement
LFG Volume
Flow to Flex
LFG Methane
Concentration
to Flex
LFG
Temperature
to Flex
Gross Power
(Bi-directional)
Total Parasitic
Load
Ambient
Temperature
Ambient
Pressure
Ambient
Relative
Humidity
Required
for:
Heat Input to
Flex
Heat Input to
Flex
Temperature
corrections
for flow and
CH4
concentration
Power
Production
Net Power
Production
Performance
relative to
ambient
conditions
Performance
relative to
ambient
conditions
Performance
relative to
ambient
conditions
Tag
LFG_Flex
CH4_Flex
Temp_Flex
PM_Gross
PM_Par
Temp_Amb
Pres_Amb
RH_Amb
Units
cfm
%
deg
F
kW
kW
deg
F
in Hg
%
Nominal
120
45
65
200
30
85
26
60
Low
24
0
0
0
0
0
30
0
High
340
100
120
250
120
120
32
100
Accuracy
2% of
reading
0.2% FS
0.2 deg F
1%of
reading
1%of
reading
1 degF
1 % FS
2.5% RH
Output
4-20
mA
4-20
mA
4-20
mA
pulse
to 4 Hz
pulse
to 4 Hz
4-20
mA
4-20
mA
4-20
mA
Power
24VDC
1A
24VDC
1A
24VDC
1A
none
none
6 to 24
Vdc
10 to
30
Vdc @
10
mA
6 to 24
Vdc
Mfg
Air Monitor
Corporation
BlueSens
Omega
Wattnode
Wattnode
Omega
Omega
Omega
Model
LO-flo/SS Pitot
Traverse Station
Model FR (4 inch
flange to 3 inch
station) with
VELTRON DPT-
plus transmitter
BCP-CH4
PR1 8-2-1 00-1/4-6
WNB-3Y-480-P
WNB-3Y-480-P
HX94AC
PX429-26BI
HX94AC

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      Table 5.  Supplementary Data to be Acquired from Integral Flex Sensors
Measurement
LFG Mass Flow
LFG Methane Concentration
Bi-directional Power
Flexidizer Inlet Temp
Flexidizer Outlet Temp
Turbine Exit Temp
Recuperator Exhaust Temp
Required for:
Flex operation + cross check on
SRI sensor
Flex operation + cross check on
SRI sensor
Flex operation + cross check on
SRI sensor
Flex system 'health' indication
Flex system 'health' indication
Flex system 'health' indication
Flex system 'health' indication +
heat recovery estimates
Tag
LFG_Flex2
CH4_Flex2
BPW_Flex
TT_GIT
TT_GET
TT_TET
TT_EGT
Units
cfm
%
kW
deg F
deg F
deg F
deg F
                            Table 6. Parasitic Loads

Flexidizer Heater Group 1
(480 V)
Flexidizer Heater Group 2
(480V)
LFG Supply Blower (480V)
Start Skid (480V) (Two
compressors, chiller,
pump and transformer).
Startup only.
Auxilliary Panel '!_' (240V)
Total
Nominal (Amps)
22
22
8
0
25
77
Nominal (kW)
10.6
10.6
3.8
0
6.0
31.0
Maximum (Amps)
22
22
8
162
40
254
Maximum (kW)
10.6
10.6
3.8
77.8
9.6
112.4
                Figure 7:  LFG Measurement Configuration Detail
f
LFG From Blower
4"SSPipe V
1 UU lk> ridliyCS — V !.£,& Hi 1 INI(J(JI
\ Flow
\ Element


-J-v CH4 ^u- g-7 DR
\Sensor g^ g^j- Po
\B £Eo:£ l
^^r i i t
-2°'-|-2°^20
= /_1"NPT Nipple
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                                     Bypass Line
ESTCP Demonstration Plan
24
February, 2011

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5.4.4 Emissions and Destruction Efficiency Testing

After approximately  1000 hours of steady state operation in full Flex mode, an emissions test will be
conducted. It is desirable to conduct the test once the system has fully stabilized and after a sufficient
period has elapsed that the  emissions measurements may be  considered representative  of normal
operations.

The emissions test will be a fully rigorous compliance test using standard EPA compliance test methods
(see Table 7 below).  Three 1-hour test runs will be conducted to determine mass emissions (e.g., Ib/hr) of
the pollutants listed in Table 7. The test is intended to demonstrate that Flex emissions meet or exceed the
most stringent applicable air quality standards (see section 3.2).

The emissions testing will be conducted by Integrity Air Monitoring, Inc. (Integrity Air).  Integrity Air is
a fully  certified emissions testing contractor. Integrity Air has performed satisfactorily on  previous
demonstration and verification projects for Southern Research.

To comply with EPA methods, the exhaust stack will be fitted with two sampling ports (4 inch ID close
nipples with caps) located at the same elevation on the stack at 90 degrees to each other.  The ports must
be located a  minimum  of two  stack  diameters downstream of any  obstruction to flow and  one half
diameter upstream.  The Flex stack is a straight run 17.8 inches inside diameter and  70.3 inches long.
Thus, centering the ports at 53.4 inches (3 diameters) downstream of the base of the stack will meet EPA
requirements.  A scaffold or platform  will be provided at 15-18 inches below the center of the ports to
provide safe access for testing personnel and support for the sampling trains.

For the emissions test, two 15 Amp 120 V circuits  will be required  near the  stack and one 480V 30 Amp
circuit will be required at the test trailer.

Destruction Efficiency

Determination  of  NMOC and  methane destruction efficiency  will be  made based  on  concurrent
concentration and flow measurements at the inlet and exhaust of the Flex.

Southern's experience with compliance testing and the experience  of Integrity Air  indicates that, to
conform with commonly accepted practice, the DRE inlet sampling location would be  in the diluted gas
stream - downstream of where  the LFG feed gas and  dilution air are mixed before entering  the  Flex
compressor. However, due to the configuration of the inlet air plenum on the IR turbine, it is not possible
to obtain a representative flow measurement of the  diluted stream.  Therefore, the inlet DRE samples will
be obtained from a port  located  in the  LFG supply line to the Flex compressor (see Figure 5) to provide
inlet NMOC mass flow  with at least as  much accuracy as  sampling  in the diluted stream. South Coast
AQMD approved the same method for the regulatory compliance test at FlexEnergy's Lamb Canyon pilot
plant [14].

The LFG supply line is  a 4 inch stainless steel pipe.  The sampling port is a 1 inch diameter pipe stub
welded to the 4 inch pipe and fitted with a 1 inch gate or ball valve. Downstream of the valve, a % inch
male NPT  nipple will be provided to attach the dilution probe.  The flow measurement will be  obtained
from Southern's flow element (LFG_Flex).

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Parameter
Volumetric Flow
CO2, SO2, NOX, and CO
Total Reduced Sulfur (TRS)
THC/NMOC
PM10/PM2.5
EPA Reference Method
1,2,3A&4
3 A, 6C, 7E & 10 (respectively)
16A (Modified to use an SO2 analyzer in place of
wet chemistry/titration)
25 A & 18 (NMOC as THC less methane)
OTM-27 and OTM-28
5.5 Sampling Protocol

The only samples to be collected for the demonstration are associated with the emissions and destruction
efficiency testing described above. All samples will be obtained in accordance with the corresponding
EPA reference or equivalent methods.

5.6 Equipment Calibration and Data Quality

5.6.1 Calibration of Equipment

All monitoring equipment installed by Southern  (see Table 4) will be newly  purchased and have a
manufacturer's calibration valid for at least the duration of the one year demonstration period.  Data
collected from these instruments is sufficient to satisfy demonstration performance objectives and meet
QA requirements.

The selected pressure/flow transmitter has the capability to automatically re-zero itself at a predetermined
interval without interrupting data acquisition. The automatic  zeroing circuit eliminates output signal drift
due to thermal, electronic or mechanical  effects, as well as the need for initial  or periodic transmitter
zeroing. The selected methane sensor uses infrared optical sensing that is inherently accurate and stable
and does  not  require recalibration. The  power meters  are equipped with status LEDs that indicate
calibration faults.

All sensors will be installed and initial  sensor function  checks  conducted according  to manufacturer
specifications.   Following installation,  source to data checks will be conducted in the field to verify that
the data acquisition properly receives and  processes incoming signals.  All checks will be documented in
field log books, digitized, and stored as part of project files.

All data will be accessible remotely via a cellular router internet connection.  During operation, sensor
data will be checked for reasonableness and consistency weekly. The methane and flow data will be cross
checked against similar  measurements  obtained  from Flex  system sensors.   Gross and net  power
production measurements will be cross checked against data from the bi-directional utility interconnect
meter.

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5.6.2 Quality Assurance

Requirements

As  this project  is funded  under the  DoD's ESTCP, this  demonstration  plan  has been prepared in
accordance with ESTCP guidance and the QA requirements therein. This project is unique; however, in
that it is also receives technical guidance and QA review support through EPA's ETV program. As such,
the  demonstration test also conforms to EPA NRMRL QA requirements.  As this project is not intended
to support  development of environmental  regulations or standards, Southern has determined that it is
appropriately classified as a NRMRL Category III project. As this project is intended to demonstrate the
performance of technologies under defined conditions, it is subject to NRMRL QAPP Requirements for
Measurement Projects.  This demonstration plan incorporates all required QA elements in EPA Guidance
for  Quality Assurance Project Plan (EPA/QA G5).

Data Quality Objectives for Critical Results

The critical results necessary to  satisfy performance  objectives are the  net power production  and
emissions measurements.  Thus, specific data quality objectives must be established and met for these
results to ensure that results are of sufficient quality to satisfy the decision making needs of Flex, ESTCP,
EPA and other stakeholders.

For power  production, the ultimate question to be answered is whether the  Flex  will produce sufficient
power to offset the capital and operation costs of the system over a reasonable period of time (5-7 years).
Thus, for the purpose of establishing a data quality objective, a  1  percent uncertainty  in monthly
aggregate power production would be a very conservative data quality objective.

The combined accuracy of the power meters and associated current transformers is  ± 1.1% for each
reading.  Readings will be taken at 5 minute or shorter intervals.  In one month (30 days), 5-minute
readings  amount to  8640  readings.   At  a nominal  200kW  output, propagating the  1.1% reading
uncertainty over one month (8640, 5-minute readings) gives a combined absolute uncertainty of ± 17
kWhr per month out of 144,000 kWhr generated,  or just over 0.01% uncertainty.  This analysis neglects
the  covariance term in the error propagation; however, this covariance should be small for steady state
operations.  This analysis demonstrates that the measurement uncertainty is far  more than adequate to
meet the needs of decision makers.

It is expected to have near 100 percent data capture for the power measurements; however, a percentage
data capture objective, by itself, is not especially relevant.  It is more important to capture changes in
power output and identify the conditions causing those changes.  Should a  power meter fail, corrective
action will be initiated immediately; however, a second power meter is integral to the Flex system and
data will be  available  to fill in any gaps.  Moreover,  if operating  conditions remain consistent (as
evidenced by Flex operating parameters that will be logged), it may be safe to assume that power output
is also consistent. In summary, the power meters are expected to be reliable, but there is more than one
backup should a meter fail.

The quality of the emissions measurements will be assured by adhering to quality assurance requirements
in the associated EPA reference methods cited above (Table  7).  The emissions test report will  include
documentation  of all calibration  and  QA/QC checks  conducted.   The data quality objective  for the
emissions measurements will be satisfied if the  EPA QA/QC requirements are documented to be met.
Achievement of QA/QC requirements will be verified by Southern's QA manager as part of the audit of
data quality. If the requirements are not met, the tests will be repeated.

The quality of all raw data from  Southern's continuous monitoring instrumentation will be assured by
observing instrument calibration, installation and data review requirements  as described above (section
5.6.1). In the event that any problems are encountered, corrective action will be immediately initiated by

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the Project Manager. All problems and corrective actions will be fully documented and the impact of any
problems on data quality will be assessed and reported.

Ancillary Data Quality

The  quality of supporting  data obtained from  Flex instrumentation (see Table  5)  and from the LFG
extraction system will be verified via reasonableness and consistency checks. Calibration certificates and
documentation of QA/QC checks will be obtained  as available.   The impact of any problems on data
quality  will  be assessed and presented in final  reports.   These supporting  data  are  not  critical
measurements and do not directly affect achievement of data quality  objectives, so stringent QA/QC
requirements are unnecessary.  That said,  these  data  do contribute  to  the  understanding of Flex
performance during the demonstration so, should any problems occur, Southern will work with Flex or
base personnel to correct the deficiency in a timely manner.

Data Review and Validation

All data will be reviewed on an ongoing (weekly) basis by project staff and classified as valid, invalid or
suspect. Data review will consist of (for example):

    •   verifying that data collection is complete for all sensors
    •   examining raw data values and trends for consistency and reasonableness,
    •   making comparisons between related measured parameters and calculated values for agreement
        within process operating parameters
    •   flagging incomplete, invalid or suspect data and documenting the reason for the flag
    •   initiating investigative  or corrective actions as needed.
In general, valid data results from measurements that meet the required QA/QC checks, are collected
when an instrument was verified as being properly calibrated and functioning, and that are consistent with
system operating parameters and reasonable expectations.

Reported results will incorporate all valid data. Analysts may or may not consider suspect data, or it may
receive  special treatment as will be specifically indicated.  The impact on data quality of any problems or
issues that arise will be  fully assessed, documented and  reported.  Any limitations on the use  of the
resulting data will be fully assessed and reported.

Data Management

Field data will be collected, stored, and retrieved from Southern's data acquisition system (DAS) at the
demonstration site. The DAS will be equipped with a web-based cellular link so that data may be
accessed and DAS settings configured remotely from any location.

Southern will retrieve data from the DAS Southern Research at the first of each week during the one year
demonstration period. The field team leader is responsible for ensuring that all electronic and hard copy
data, forms and logs are accounted for, properly completed and stored in project files according to the
Southern Research Quality Management Plan and other applicable policies and procedures. The project
manager will periodically review project files and verify that all data, reference sources, critical project
documents and correspondence necessary to support the data analysis and reporting are accounted for.
Before results are reported, the QA manager will conduct an audit of data quality; which includes
verifying that all results can be traced to raw data and supporting documentation.

Raw data will be compiled into spreadsheets for analysis with links or references to the original data
source and storage location. All analyses and calculations will reference conversion factors and constants
from known sources properly identified within the analytical spreadsheets.

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Independent Review

Southern's QA manager (QAM) is administratively independent from project management.

The QAM has reviewed this demonstration plan to ensure that it fully satisfies project objectives and
complies with ESTCP guidance and EPA/ETV QMP requirements.

On a monthly basis during the demonstration period, the  QAM will  verify with project  staff and
management that data reviews and all  required QA/QC activities have  been completed and that any
necessary corrective actions have been implemented.  The QAM will be notified by the project manager
whenever a data  quality problem is encountered and the QAM may assist in assessing and documenting
the impact on data quality of any such problems.

At the completion of the demonstration, the QAM will conduct an audit of data quality (ADQ).   The
ADQ consists of following each data stream from raw data to  final results to ensure that all required
QA/QC is complete and documented, and that calculations are correct and  results and uncertainties
correctly reported.  The QAM will also review the final report  to ensure that reported  results and
uncertainties accurately reflect the data collected.

All QAM reviews and audits will be documented in memoranda submitted to the project manager.


6.0 PERFORMANCE ASSESSMENT

The following sections describe the analyses and computations required  to obtain final results for each
performance objective from the  data collected as described in sections 3 and 5.

A number of the analyses  described  below depend  on the definition of steady state Flex operations.
Steady state operation has been  defined by Flex as periods when the Flex is operating in full 'Flex mode',
that is, when the  startup equipment is no  longer operational and the Flex is running from dilute LFG only.
It is possible that there will be some variation in power production or generating efficiency during steady
state conditions.  During commissioning, quantitative steady state operating conditions (such as oxidizer
temperatures) will be determined by Flex engineers, so that data analyses will be well defined.

6.1 Power Production

The following quantities are of interest in the analysis of the power production data:
       Peak gross and net power production
       Sustained or steady state net power production
       Net annual power production.
Net power production during any given time interval is the gross power production less the parasitic load.
The peak power production will be reported as the average of the upper 5% of logged power data. The
number of hours at this production will also be reported. Sustained power production will be reported as
the power production  range that is maintained during  periods of steady state operation as defined by
FlexEnergy engineers (e.g., in terms of Flexidizer temperature bands). Annual power production will be
computed as the integral (summation) of power production over logged time periods (e.g., 5 minute) over
the one year demonstration period.

Net annual power production will also be reported minus the energy consumed in the form of propane
startup fuel. The startup fuel energy will be calculated  by multiplying the total amount of propane used

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for startups during the year, by the heat content of propane (e.g., 12,600 BTU/lb) converted to kWh (3413
BTU/kWh).

As discussed above  (section 5.6.2), during steady state operations, the propagated uncertainty in net
power production computations decreases as more data are collected over time.  Since the uncertainty in a
single measurement  of power production is only  slightly more than 1 percent, the uncertainty in the
aggregate power production over a period as short as one day is very small (ca. 0.1% or smaller).

Results  will be obtained as described below for the related  supplementary objectives of determining
generating  efficiency, ambient  condition dependent  or seasonal  de-rating  curves, and  heat recovery
potential.

Generating Efficiency

The product of LFG flow  (scfrn), methane concentration,  and the heat content of methane gas (1012
BTU/scf) gives the heat input to the Flex in BTU per unit time (e.g., BTU/hr). The generating efficiency
of the Flex is the power generated (kWh/BTU) divided by the heat input (BTU).

Steady state generating efficiency will be computed as the average generating efficiency over steady state
periods  of operation.  The  analysis will seek to characterize and determine the  causes of any changes
observed in generating efficiency during nominally steady state operations.

Overall  generating efficiency will be computed over a period to include one  start up  cycle (when net
power production is negative) and  3 months (0.25 year or 2190 hours) of steady state operation (when net
power production is positive). A cold startup is assumed to be necessary no more than 4 times per year.
Startup  fuel use will be taken into account in determining average generating efficiency as described
above.

Seasonal de-rating

The Flex is expected to generate less power when ambient temperature is high, absolute humidity is low
or barometric pressure is low. At Ft. Benning, seasonal variation in temperature is expected to have the
largest effect.   Southern will develop a seasonal de-rating  curve  showing the relationship of ambient
temperature to power output once humidity and barometric pressure effects (if significant) have been
removed.

Heat Recovery Potential

The Flex unit to be demonstrated at the  1st Division Rd.  Landfill will not be equipped with heat recovery
equipment as there is no local use for  the recovered heat; however, it is of interest to know the heat
recovery potential if this option were installed.

The heat recovery rate (BTU/hr) is calculated as the product of (1) the heat recovery fluid flow (gal/hr),
(2) difference between supply and return temperatures from the heat exchanger  (deg F), (3) heat capacity
of the heat recovery fluid (BTU/lb  deg F) and (4) heat recovery fluid density (Ib/gal).

The exhaust gas temperature will be monitored.  The exhaust gas mass flow will be measured during the
emissions test at steady  state conditions.  These values will be applied along  with Ingersoll Rand heat
exchanger  specifications and reasonable  assumptions on the heat recovery fluid  flow and inlet
temperature to arrive  at an estimate of heat recovery.

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6.2 Emissions

Pollutant emission rate calculations (Ib/hr) will be made according to standard EPA methods referenced in
section  5.4.4,  above.   Emission rates in terms of Ib/MWhr  will be computed by  dividing the Ib/hr
emission rates by the steady state power production in MW over one hour.

Mass  emission rates will be assessed against regulatory limits and emission rates from alternate LFG
utilization technologies as described in section 3.2 above.

6.3 Destruction Efficiency

Methane and NMOC destruction efficiency will be determined as described in Section 5.4.4 above.  The
results will be reported and compared with regulatory limits and best alternate control technologies as
described in section 3.3 above.

6.4 Greenhouse Gas Reductions

As discussed above (section 3.4), the only significant GHG reduction attributable to the Flex is the utility
generation offset due to the power produced by the Flex.

The annual GHG reduction (metric tons  CO2e) is based on avoided emissions for utility electric power
generation for the State of Georgia. Emission factors for carbon dioxide, methane, and nitrous oxide from
the most recent eGrid database will be weighted by current EPA accepted global warming potentials (e.g.,
Table ES-1 in EPA's 2010 GHG Inventory) [11] to arrive at the total combined CO2e emission factor in
metric tons/MWh.  Currently, this factor is 0.64 metric tons CO2e/MWh.  This is shown in the equation
below.

R_avoided (metric ton CChe) = Q (MWh) x EF(metric ton CChe/MWh)

Where,
    •    R_avoided are the utility emissions offset by power generation from landfill gas
    •    Q is the electric energy produced during the one year demonstration period.
    •    EF is the combined  GHG emission factor

    (Alternate equation  text):  utility emissions offset by power generation from landfill gas is equivalent to the
    electric energy produced during the one year demonstration  period times  the combined greenhouse gas
    emissions factor
To determine percentage GHG reduction, the avoided emissions due to power generation are  divided by
the direct emission reduction due to destruction of methane. The percentage reduction is  the additional
GHG reduction due to avoided utility emissions as a proportion of the emissions reduction  due to the
destruction of methane. This is shown in the equation below.

 A     1 ^TT^ ™  1   •   /           -.   R   avoided , nn
Annual GHG Reduction (percentage) = —=	x 100
                                        R_direct

Where,
    •    R_direct are the GHG emissions reduction due to the destruction of methane
(Alternate equation text):  annual percent greenhouse gas emissions reduction is equivalent to greenhouse gas
emissions avoided divided by technology direct greenhouse gas emissions, times 100

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Any difference in methane destruction efficiency between the flare and the Flex is not accounted for.  It is
assumed that the flare and the Flex have the same (near complete) methane destruction efficiency.  In any
case, it is not possible to determine the methane destruction efficiency of the open, candlestick flare. The
direct and avoided GHG emissions reductions are calculated using formulae adapted from EPA's LMOP
GHG emissions reduction calculator. [8]

6.5 Economics

The life cycle economic performance of the Flex will be assessed based on standard economic indicators
of financial performance including the net present value, and simple payback period. These indicators are
derived from a cash flow analysis accounting for initial capital costs, ongoing operation and maintenance
costs, and revenues  representing the value of the power produced by the Flex system over the projected
useful life of the system.  Costs specifically associated with the demonstration program will be excluded
as non-typical of a normal installation.

Details on the economic performance criteria, data collection, and analysis are provided in Section 7.0

6.6 Operability - Availability, Reliability  and Ease of Use

In order to be successful,  the Flex system must provide sufficient availability, reliability and ease of use
so that the economic value of power production is realized and no undue  burden is placed on operations
staff.  The Flex is intended to operate on a 24x7 basis with a level of attention similar to or lower than the
level of attention generally required by similar LFG-to-energy equipment.  Projected economics are based
on periodic minor scheduled maintenance and infrequent unscheduled down time, as well the projected
cost and down time associated with a major overhaul.

Availability is a quantitative metric that is given as the percentage of  time that the system is either
operating  or capable of operation if down for unrelated reasons (such as  power failure or failure of the
LFG collection  system).   Reliability  is both  a quantitative and qualitative metric that  assesses the
robustness of the system  in terms of likelihood of failure or operational problems, the consequences of
such problems, and  the ability to recover.  Availability and reliability will be assessed quantitatively in
accordance with ANSI Standard 762 which uses  a specific categorization of operating and  downtime
hours.   Reliability  will also be assessed qualitatively based on  the  operating experience of project
participants  (including  Southern Research,  Flex and  local operators).   Qualitative  reliability will be
documented with narrative descriptions prepared by Southern Research  and Flex and interviews with
operating staff at the conclusion of the project.

To assess reliability, the following service parameters will be logged by Flex Energy operations staff.

    •    Service Hours (SH) = Hours unit is in actual operation or fully available for operation;
    •    Reserve  Shutdown Hours  (RSH) = Hours unit is  shut down by choice, but could otherwise be
        available for operation;
    •    Planned Outage Hours (POH) = Hours  for a shutdown defined in advance (i.e. site maintenance
        activities, inspection of components, planned system upgrades, etc.)
    •    Forced Outage Hours (FOH) = Hours for a shutdown period beyond the control of the operator -
        typically an  immediate shutdown is required;
    •    Maintenance Outage Hours (MOH)  =  Hours for a shutdown due to a condition that requires
        shutdown prior to the next planned outage;
    •    Period Hours (PH) = total hours for a specified period = SH +  RSH + POH + FOH + MOH

For any time period  in which the system is not operating, the log will be completed and hours categorized
in accordance with the above definitions.

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Categories of down time may include:

    •   Turbine/Flex system failure/unscheduled maintenance
    •   Generator system failure/unscheduled maintenance
    •   Electrical/interconnection system failure/unscheduled maintenance
    •   Gas collection system failure/unscheduled maintenance
    •   Turbine system scheduled maintenance
    •   Generator system scheduled maintenance
    •   Gas collection system scheduled maintenance
    •   Safety shutdown (weather, fire, or other external reason)
    •   Other non-technical shutdown (commanded by base or other authorities).
Southern's analysts will review operational data for the system and maintenance logs  and ensure any
periods of shutdowns as observed in the data are properly documented in the logs.  Analysts will also
review the description of the outage  hours to ensure that outage periods are properly categorized.   Once
categorized and reviewed, analysts will calculate the Reliability and Availability as follows:

Reliability       =        1-(Forced Outage Rate)
                          Period Hours (PH) - Forced Outage Hours (TOFT)
                                         Period Hours (PH)
(Alternate equation text):  System reliability is equivalent to period hours minus forced outage  hours divided by
period hours

Availability      =        Service Hours (SH) + Reserve Shutdown Hours (RSH)
                                         Period Hours (PH)
(Alternate equation text):  System availability is equivalent to service hours minus reserve shutdown hours divided
by period hours

The operational log for the  system will be maintained by Flex Energy operations staff and contain entries
for each  event or occasion when the system  is inspected, adjusted, maintained, repaired or requires
attention in any way.  The log will be reviewed regularly (at least monthly) by Southern project staff.

Each entry will contain:

    •   Date/Time
    •   Names of the  observer and participants in the event
    •   What alerted staff to the event - e.g., routine inspection, system alarm, notification
    •   Description of the event
    •   Cause of the event
    •   Actions taken including all steps leading to resolution
    •   Staff time and material resources required to resolve the event
    •   Service time parameters as defined above
    •   Comments on how  easily the situation was resolved and any problems encountered.
In addition,  system operators will be interviewed by Southern project staff upon system installation after
receiving training, during  periodic  reviews  of the log,  and  at the end of the extended test period.
Interviews will be documented and stored as part of project files.

Finally,  ease of  use  is a  qualitative  metric  that will be  based  on operating  experience during the
demonstration period  as documented by narratives and  interviews with operators  and project participants
during and at the  conclusion of the project. The acceptability of a newly introduced technology is partly
dependent on the subjective  experience  of operations  and maintenance personnel.  If  these personnel
require  highly  specialized  training the cost of training  and operations increases,  and availability is

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reduced.  When the system  fails, someone with the needed  expertise  is unlikely to  be immediately
available.

7.0 Economics	

The purpose of this section is to identify the information that will be tracked during the demonstration and
the methods that will be employed to establish realistic life cycle costs for implementing the technology.
Table 8  provides an inventory  of cost elements associated with  the life cycle analysis along with a
description of the data to be tracked and identification of the source of this information.

A number of resources have been used to guide the life cycle assessment approach for this demonstration.
EPA's LMOP Handbook Chapter 4, Project Economics and Financing [15] provided general guidance on
evaluating economics for landfill gas to energy projects.  EPA's LMOP LFG_Cost model has been used
as a guide to identify cost elements and default values particular to landfill gas to energy projects and may
also be used to generate estimated costs for comparable technologies. The Environmental Cost Analysis
Methodology Handbook [16] has also been consulted as a guide to  conducting economic analyses where
environmental costs are a factor.  Though designed for buildings, the NIST Building  Life Cycle Cost
(BLCC)  software [20] has applicability for renewable energy projects and Southern has determined that
the BLCC software may be used to calculate LCC assessment parameters for this  demonstration. Life
cycle  costing methods and data from NIST Handbook  135 [21] have been referenced  in preparing the
economic analysis approach.

Life Cycle Assessment

The simplified life cycle economic analysis will be based on capital  and operation /maintenance costs and
revenues associated with electricity production during the demonstration period and  projected over the
expected life of the Flex unit.  Costs specifically  associated  with the demonstration program or with
product development will be  excluded as non-typical of a normal installation. The analysis is 'simplified'
in the sense that it will not account for costs associated with financing or taxes, or for revenues associated
with renewable energy credits, tax credits or incentives that may be available in some locales for landfill
gas to energy or other waste to energy projects.

The life cycle economic performance of the Flex will be assessed based on standard economic indicators
of financial performance including the net present value (NPV), internal rate of return (IRR) and simple
payback  period.  These indicators are derived from cash flow  analysis accounting for initial capital and
installation costs, ongoing operation and maintenance costs, and revenues representing  the value of the
power produced by the Flex  system over the projected useful life of the system.  Current discount rates
from OMB Circular A-94, Appendix C [22] will be applied. The 20-year real (non-inflated) discount rate
for 2010  is 2.7%.

According  to modeling predictions  [12], the  1st Division  Road  Landfill  should continue producing
sufficient gas for Flex operations through 2020-2025 or longer.  According to FlexEnergy, in a typical
installation, the Flex should  provide  service for 20 years or longer.  For the purpose of the economic
assessment, the lifetime will initially be assumed as  20 years; however, this figure may be adjusted based
on experience gained during the demonstration.

Revenues

At Fort Benning, the current value of electric power is $62/MW h.  The  incremental value of renewable
power is assessed at $45/MWh.  [17] Thus, the value of electric power produced today is $107/MWh, or
nominally $150,000 per year for the Flex 200 unit.  For future years, the value of electric power will be
adjusted  using GA Power avoided cost projections [18] and projected fuel price indices  from the current

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annual supplement to the Life Cycle Costing Manual for Federal Energy Management Projects [NIST
135].

Scaling

Because the demonstration system is an actual full scale implementation of the technology, scaling is not
a major concern.  For application to larger landfill sites with greater rates of gas extraction, there may be
savings associated with deployment of more than one Flex unit. Southern will work with FlexEnergy to
develop costing guidelines for such installations. These guidelines will not be included in the performance
assessment report, but will be incorporated in guidance documents and outreach tools.

Assumptions

Flex Energy staff and contractors will support operation and maintainance of the Ft. Benning installation
remotely and with intermittent on-site support during the first year of operations. Minimal on-site
staffing support by Ft. Benning will be required for operation. Ft. Benning will assume ownership and
responsibility for operations and maintenance from the end of the demonstration period forward.  Flex
Energy will provide operations and maintenance training to Ft. Benning staff or contractors before the end
of the demonstration period.

The analysis will be completed in constant dollars (excluding inflation).  Therefore, all discount rates and
price escalation rates will be entered in real terms (no inflation).

Initial investment costs will be assumed to be phased over a planning/construction/installation period
equivalent, for this project, to the planned one-year period from 4/15/2010 - 4/15/2011.
Cost Element
Description
Data Tracked During
Demonstration
Data Source
Investment (Capital) Costs
Hardware capital costs
Design and Engineering
Costs
Supervision, Inspection,
& Overhead Costs
Direct costs for
equipment and supplies
associated with the
system
Costs associated with
typical engineering,
equipment specification,
engineering design,
permitting. Does not
include site selection
costs. Does not include
development costs.
Costs associated with
supervision of the
project (project
management),
inspections for
permit/code compliance,
permit fees, and
Actual equipment and
supply costs for the
demonstration
installation
If costs are tracked
separately by
FlexEnergy, actual
costs will be specified.
Otherwise, costs may
be estimated as a
percentage of total
capital investment
costs.
If costs are tracked
separately by
FlexEnergy, actual
costs will be specified.
Otherwise, costs may
be estimated as a
percentage of total
FlexEnergy accounting
(to be modified to add
any costs discounted or
remove costs
specifically required for
the demonstration
program)
FlexEnergy accounting
or estimates of
engineering labor
hours/rates or
representative default
values.
FlexEnergy accounting
or estimates of
supervisory labor
hours/rates or
representative default
values.

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Cost Element
Description
Data Tracked During
Demonstration
Data Source
                        overhead charges by
                        supplier.
                        capital investment
                        costs.
Site Preparation Costs
Costs for grading, pads,
fencing and utility
interconnection.
Actual costs
FlexEnergy accounting
and Ft. Benning
contributions to site
work.
Salvage Value
Residual value of any
equipment at the end of
service life - may
include scrappage or
resale, or may include
offset of future costs if
life of a specific
component is beyond
the overall system
service life
None - assumed to be
zero.
Installation costs
Costs associated with
the installation of the
system, including site
work, construction,
commissioning, and
startup costs.	
Labor & materials
required to install
(actual and projected for
commercial installation)
FlexEnergy accounting.
                               Operation and Maintenance Costs
Routine system
monitoring and
supervision.
Periodic review of
system operating
parameters, response to
remote alarms,
adjustments to
operating parameters as
needed. Routine project
management.	
FlexEnergy or other
operational staff (i.e., Ft.
Benning) time.
FlexEnergy labor hours
log or estimate.
Consumables
Regularly used products
(non-utility) that are
consumed during
normal use and must be
replaced.
Methane used for
system startup.  Oil,
coolant and other
consumables for turbine
operation. Cost of
oxidizer media is part of
major overhaul cost.
FlexEnergy accounting.
Maintenance
Includes both scheduled
and unscheduled
maintenance activities
required for Flex
operation.
Frequency and costs of
actual maintenance
during demonstration
period, including labor
hours, parts, supplies
and subcontracts.
Operations and
Maintenance Monitoring
Log.
Major Overhaul
Costs for major
overhaul
(labor/parts/supplies)
and any costs or loss of
revenue for associated
downtime.
Estimates to be made
based on oxidizer and
turbine degradation
during demonstration,
plus manufacturer's
judgment.	
FlexEnergy and
Ingersoll-Rand
estimates.

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Cost Element
Hardware lifetime
Operator training
Description
Useful life of the system
required for
determination of
lifecycle anaylsis time
frame
Formal training of on-
site operators and
mechanics to maintain
and operate the system
during normal operation.
Data Tracked During
Demonstration
Estimate based on
component and oxidizer
media degradation
during the
demonstration and/or
manufacturer's
estimates.
Operator training costs
(labor for trainer and
operators).
Data Source
FlexEnergy and
Ingersoll-Rand
estimates.
Flex accounting and
operator labor rate
estimates.
Revenues
Energy production
Value of electricity
produced by the Flex
and used within Ft.
Benning, including a
renewable energy
premium.
Electric power
production (MWh) and
electricty prices,
escalation rates and
incremental value of
renewable energy.
Power metering,
electricity prices and
escalation rates from
sources cited above.
Premium rates for
renewable energy from
DoD and other sources.

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8.0 SCHEDULE OF ACTIVITIES
Figure 8 provides a summary of the tasks and schedule for all project activities.  The projected schedule includes equipment installation beginning
in November, 2010, testing initiated in April, 2011 and continuing through April, 2012, with data analysis and reporting occuring in mid 2012.
ID


77

85
86
89
92
95
99
104
112
119
120
121
125
137
143
206
210


»




















Task Name

Task 1. Project Management
Ph 1-Task 2: LFG Database S Site Selection

System Design
Pieliminaiy Flex Design
Pi elim site design
Detailed Flex Design
Detailed Site Design
Permitting
Flex System Pi ocui ement :Mf g
Site Prep 3 Installation
Operation & Maintenance
Ph 1-Task 4: Demo i Validate
Demonstration Plan
Instrumentation £ Comms
Controlled Test
Extended Test
Operator Survey
Analysis & Reporting


Gtr2 | Qtr3 | Qtr 4

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2009 2010 2011 2012 2013
Qtr 1 | Qtr 2 | Qtr 3 I Qtr 4 Qtr 1 I Qtr 2 | Qtr 3 Qtr 4 Qtr 1 Qtr 2 Qtr 3 Qtr 4 Qtr 1 | Qtr 2 Qtr 3 Qtr 4 Qtr 1 | Qtr 2 |
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9.0 MANAGEMENT AND STAFFING
Figure 9 provides an organization chart for the project staffing. All project team members will report to the
Principal Investigator.  Staff identified are qualified for the assignments indicated based on educational and on-the-
job training experience in demonstration, assessment, analysis, and QA activities. Descriptions of the
responsibilities and qualifications of staff are provided in the following section.
                                         ESTCP Water & Energy
                                            Program Manager
                                            Dr. James Galvin
              ETV GHG Technology
             Center Program Director
              Lee Beck, USEPA/ORD
         Principal Investigator
             Tim Hansen
          Southern Research
               Quality Assurance
                  Eric Ringler
              Southern Research
              EPA Quality Assurance
                      Staff
      Host Site Project Manager
           Anna Butler
      USAGE Savannah District
Technology Developer
Paul Fukumoto
Flex Energy

Field Team Leader
Wes Kowalczuk
Southern Research
                                                   Data Analyst
                                                   Dave Smith
                                                Southern Research
          Host Site POC
          Dorinda Morpeth
        USAGE Ft. Benning
  Project Manager
Charlie Pattabongse
   Flex Energy
  Emissions Testing
   Rob Callahan
Integrity Air Monitoring
                          Figure 9. Project Organization and Staffing

    Tim Hansen is the Principal Investigator and GHG Technology Center Director. He will:


    •   ensure manpower and material resources are available to complete the demonstration
    •   oversee staff and provide management support
    •   contribute technical expertise and provide guidance to the development and implementation of
        the demonstration plan, analysis of the data, and reporting of results
    •   interact with stakeholders, vendors and contractors to ensure goals and milestones are met and
        maintain effective communications between all participants
    •   submit Quarterly Progress Reports and Monthly Financial Reports to ESTCP
    •   review the Demonstration Plan, Final Technical Report and Cost and Performance Report to
        ensure they conform to ESCTP guidance and ETV principles. Submit these reports to ESTCP
    •   manage day to day project activities and track the project schedule and budget
    •   ensure that manpower and material resources are effectively deployed to achieve project activities
    •   assist in the preparation of Quarterly Progress Reports and Monthly Financial Reports
    •   ensure that the Demonstration Plan,  Final Technical Report and Cost and Performance Report are
        prepared according to ESTCP guidelines and properly submitted for technical and QA review and
        approval
    •   verify that project data and other files are properly collected and stored
    ESTCP Demonstration Plan

                                           February, 2011

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    •  verify that collected data are regularly reviewed and validated as required and that any problems
       are identified and effectively addressed
    •  ensure that data analyses are properly conducted in a timely manner and that uncertainties in the
       data are quantified or adequately characterized and fully reported
    •  ensure that corrective action is initiated for all issues identified, that problems are resolved and
       that the impact on data quality is assessed and reported.
Wes Kowalczuk will serve as the Field Team Leader. He will:

    •  provide field support for activities related to all measurements and data collected
    •  install and operate measurement instruments
    •  collect samples and coordinate sample analysis with the laboratory or testing sub-contractors
    •  ensure that QA / QC procedures and documentation requirements are adhered to
    •  identify any problems and initiate corrective  actions.

David Smith will serve as the data analyst. He will:
    •  download and otherwise obtain data at prescribed intervals
    •  review data for completeness and validity
    •  flag any invalid or suspect data and initiate corrective action as  required
    •  set up data analysis spreadsheets in accordance with this plan
    •  prepare data summaries and report tables.

The GHG Technology Center QA Manager, Eric Ringler, is administratively independent from the GHG
Center Director and project management.  Mr. Ringler will:

    •  ensure that all measurements and testing are performed in compliance with the requirements of
       this plan
    •  review test results and ensure that applicable internal assessments are conducted
    •  assess whether overall data quality is sufficient to satisfy each performance objective
    •  conduct or supervise an audit of data quality
    •  document all audit results and submit these to the Project Manager and Principal Investigator
    •  ensure that the impact on data quality of any  problems is properly assessed, documented and
       reported
    •  review and approve the  demonstration plan and final reports.

Rob Callahan of Integrity Air Monitoring, Inc. will oversee emissions and NMOC destruction efficiency
testing according to EPA methods as described in section 5.4.4 of this plan.

EPA NRMRL staff, under the direction of Mr. Lee Beck will provide review and oversight activities
including review and comment on the demonstration plan and final Demonstration Report and  Cost and
Performance Report.

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10.0 REFERENCES
[1]. Amendments to the Distributed Generation Certification Regulation, California Code of Regulations, Sections
94200-94214. 2006.

[2]. Permit to Construct and Operate Experimental Research Operations. Application number 478319. South Coast
Air Quality Management District, Diamond Bar, CA. July 3, 2008.

[3]. Rules for Air Quality  Control, Chapter 391-3-1  (2)  (mmm).  Georgia Department of Natural  Resources
Environmental Protection Division, Air Protection Branch. Atlanta, Georgia. July 20, 2005

[4]. USEPA. Title 40: Part 60—Standards of Performance for New Stationary Sources.

Subpart GG—Standards of Performance for Stationary Gas Turbines.

[5]. USEPA. AP42. Section 2.4 Municipal Solid Waste Landfills. Draft update 2008.

[6]. USEPA. LMOP. http://www.epa.gov/lmop/faq/public.html.

[7]. SCS Engineers. Current MSW Industry Position and State of the Practice on Methane Destruction Efficiency in
Flares, Turbines, and Engines. Presented to: Solid Waste Industry for Climate Solutions, (SWICS). July, 2007.

[8].  USEPA.  LMOP.   LFGE Benefits  Calculator,  http://www.epa.gov/lmop/projects-candidates/lfge-
calculator.html. 2010.

[9]. FlareGas.  Commissioning and Operating Instructions for Flaregas FN-8 Landfill Elevated Flare Equipment.
May 1, 2004.  Included as Appendix to:  Revised  Operation and Maintenance Manual, First Division Road Gas
Extraction System Installation, Ft. Benning Georgia by Home Engineering Services. August 2004.

[10]. E.H. Pechan & Associates, Inc. The Emissions & Generation Resource Integrated Database (eGRID) for 2007,
September 2008

[11]. USEPA. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2008

EPA430-R-10-006, April 15, 2010.

[12]. Home Engineering Services, Inc. White Paper: Closed First Division Road Landfill Gas Mitigation Approach.
February 2003.

[13]. Southern Research Institute. Distributed Generation and Combined Heat and Power Field Testing Protocol.
Research Triangle  Park,  NC.  Association of  State Energy  Research and  Technology Transfer  Institutions
(ASERTTI), 2004.

[14]. URS. Source Test Report Flex-Microturbine (Flexpowerstation) Lamb Canyon Landfill Performance Testing.
SCAQMD Permit To Construct And Operate Experimental Research Operations A/N 478319. URS Project No.
29874785.00001. August 17, 2010.

[15]. USEPA. LMOP. Project Development Handbook, http://www.epa.gov/lmop/publications-tools/handbook.html.

[16]. NDCEE - National Defense Center for Environmental Excellence. Environmental  Cost Analysis Methodology
(ECAM) Handbook. Johnstown, PA : Department of Defense, Deputy Undersecretary of Defense for Environmental
Security (DUSD-ES), 1999. ContractDAAA21-93-C-0046 /TaskN.098.

[17]. Communication from Vernon Duck, Ft. Benning Energy Manager in on-site meeting September 9, 2010.

[18]. Georgia Power Company. Qualified Facility Basics Package.

[19]. Canmet Energy/RETScreen International. RETScreen Clean ENergy Project Analysis Software. Ottawa,
Ontario, Canada : Minister of Natural Resources Canada, 2009. RETScreen4.

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[20]. Building Life-Cycle Cost BLCC 5.3-09. Office of Applied Economics, Building and Fire Research
Laboratory. National Institute of Standards and Technology, April 2009

[21]. NIST Handbook 135, Life Cycle Costing Manual for the Federal Energy Management. Program,
Building and Fire Research Laboratory, Office of Applied Economics, 1996.

[22]. OMB Circular A-94 Appendix C, Discount Rates For Cost-Effectiveness, Lease Purchase, And
Related Analyses, Office of Management and Budget.  Published online at
http://www.whitehouse.gov/omb/circulars_a094_a94_appx-c/

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APPENDICES
Appendix A: Points of Contact
Appendix B: Draft Health and Safety Plan (HASP)

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Appendix A: Points of Contact
NAME
Tim Hansen
Paul Fukumoto
Anna Butler
Dorinda Mopeth
ORGANIZATION
Southern Research
Flex Energy
USACE-Savannah
District
USAGE, Fort
Benning, GA
PHONE
919-282-1052
949-636-7023
912-652-5515
706-545-5337
ROLE
Principal Investigator
Program Manager
Technical Manager
Environmental
Progam Manager

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Appendix B: Draft Health and Safety Plan (to be modified based on Ft.
Benning Requirements)
Site Name:
Address:
Contact Name 1:
Contact Phone:
Contact Name 2:
Contact Phone:
Contact Name 3:
Contact Phone

1st Division Road
Landfill
Ft. Benning, GA
Dorinda Morpeth
706-545-5337
Anna Butler
912-652-5515
Fred Portofe
813-917-7534

Southern Research Site Personnel:
Namel:
Home
Phone:
Name2:
Home
Phone:





Local
Hospital:
Address:
Phone:
Medical Center
710 Center St. Columbus, GA
(706) 571-1000
Southern Research Safety Officer:
Southern Research Office Contact:
Southern Research Backup Contact:
John Baker
919-282-1055
Jennifer Lewis
919-282-1050 Ext. 0
Tim Hansen;
919-282-1052
    Work Description: Install and operate field measurement equipment
    Expected Hazards, Hazardous Conditions, or Potentially Hazardous Systems:
    CD Flying fragments, dust, or dirt              d Splashes or spills
    CD Extreme ambient heat or cold               d Breathing or atmospheric hazard
    O Illumination or work lighting               Q Radiation (IR) Hazards
    ^ Climbing, scaffolding, or access            ^ Electrical wiring
    ^ Lifting or material moving                 ^ Power systems; 480 VAC
    CD Noise                               ^ Falling objects, bumps, pinch points
    Engineering, Personal Protective Equipment, or other methods to address each
    expected hazard checked above:

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IMPORTANT: All Southern Research field personnel must wear long sleeve shirts, trousers,
and leather or other hard closed-toe shoes (not tennis or running shoes) during testing.  Rings and
other jewelry should be removed during field activities.  Head coverings are recommended at all
times.

— Climbing, scaffolding, or access: Climbing to install and remove test equipment, as well as
during testing, will be unavoidable. Southern Research site personnel will exercise extreme
caution and will seek assistance from local site personnel.  Southern personnel also have a
lanyard and harness that they will take with them to use if necessary.

— Lifting or material moving: Manual handling of the packed boxes is unavoidable, and they
will be heavy. Southern Research site personnel will seek local assistance if necessary to move
heavy items.

— Electrical wiring: A qualified electrician will make all connections for power meters involving
high voltage.  Southern personnel will only be involved in installation of low voltage signal
cabling.

All Southern  Research personnel and contractors will comply with  site standards and
requirements  regarding personal protective gear and safe operating practices. Southern Research
personnel will comply with all Southern Research Standard Operating and Safety procedures. In
addition adequate precautions will be taken to protect against insect bites and sunburn.  Site
incident reporting requirements  and procedures will be obtained and attached to this document
before work commences.

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                     Figure 8: Emergency Services Location
The nearest pharmacy is at the Center Pharmacy at 1005 Tallbottom Road Columbus, GA.
(Phone: (706) 327-8967.) The pharmacy is located 11.2 miles from the host site. Medical
Center, at 710 Center St. Columbus, GA Phone: (706) 571-1000 is the nearest hospital
emergency ward located 11 miles from the host site. Both are marked on Figure 4.
ESTCP Demonstration Plan
                                   ;
February, 2011

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