AQ_F_0400052_20180607_ST_RvwLtr

1 ROY COOPER
Governor
j MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZIN KDireAo
ENVIRONMENTAL QUALITY
6 June 2018
Tyler Fitzgerald
District Manager
Anson County Waste Management Facility
375 Dozer Drive
Polkton,NC 28135
,1
SUBJECT: Central Office Review of Source Test Result-Tier 2 Non-Methane Organic
Compounds Testing of Municipal Solid Waste Landfill (ID No. ES-1)
Air Quality Permit No. 09835T03
Anson County Waste Management Facility
_ Polkton,North Carolina, Anson County
Facility ID: 0400052 Fee Class: Title V
Dear Mr. Fitzgerald:
The Division has reviewed your source test report that was received by our Central Office on
3 January 2017. There was one report that was submitted for the Tier 2 Non-Methane Organic
Compounds(NMOC)testing,to determine a site specific NMOC concentration for the Municipal Solid
Waste Landfill(ID No. ES-1), which was conducted on 14-15 November 2016. On 15 May 2018,this
Division determined that the subject testing performed at your facility was an acceptable source test. The
review determined that compliance with the applicable emission standard is indicated for this source. A
copy of the determination memorandum, issued by Mr. Gregg O'Neal,of the N.C. Division of Air
Quality, Stationary Source Compliance Branch, is attached.
Additional information in the 2017 Annual Report submitted to this office on 27 March 2018,
indicates that the 5-year projected emission rates have changed since the above-mentioned test results
were submitted. The report stated that the actual waste acceptance rate exceeded the projected waste
acceptance rate which increased the projected emission rates;therefore, an annual report will be
submitted for each subsequent year,using the approved Tier 2 NMOC concentration in the emission rate
calculation.
Should you have any questions regarding this matter,please contact Mr. Mitchell Revels,
Environmental Chemist, at(910)433-3300, in the Fayetteville Regional Office.
Sincerely,
...
leather S.�Cartr
_
Regional Air Quality Supervisor
Fayetteville Regional Office
HSC\jdc
Attachment: DAQ RCO review(1),dated 15 May 2018 [2016-245ST]
cc:El FRO Files(with attachment)
State of North Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
910 433 3300 T 1 910 485 7467 F

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DIVISION OF AIR QUALITY
a Technical Services Section
May 15, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch(SSCB)
Subject: Anson County Waste Management Facility(ACWMF)
Facility ID 0400052, Tracking No.2016-245ST
Polkton,Anson County, North Carolina, Air Permit No. 09835T03
NSPS Subpart WWW, Nonmethane Organic Compounds(NMOC)
Tier 2 Emissions Testing of the Municipal Solid Waste Landfill(ID No.ES-1)
For a Site-Specific NMOC Concentration and NMOC Emissions Rate
Performed November 14 through 15, 2016 by Franklin Engineers&Consultants, LLC
A report of the subject testing has been reviewed and has been found acceptable for modeling
the emissions from the ACWMF. ES-1 is a municipal solid waste landfill with an associated gas
collection and control system (GCCS-1). ACWMF currently has approximately 22.4 hectares of
landfill area. Approximately 10.1 hectares (45.1%)is controlled by a Gas Collection and Control
System (GCCS)and 12.3 hectares(54.9%) is uncontrolled. Sampling was performed using a
combination sampling procedure. The results appear reliable to determine the compliance
status with respect to the applicable emissions standard.
The emissions standard that applies is 40 CFR 60 Subpart W W W Standards of Performance for
Municipal Solid Waste landfills. When the Tier 1 NMOC emission rate calculated with the
default values exceeds 50 megagrams per year(Mg/yr), the owner or operator of the landfill
must either install equipment to reduce emissions or conduct Tier 2 testing to determine a
site-specific NMOC concentration. This NMOC concentration value is used when calculating the
annual NMOC emission rate with the equations in 40 CFR 60.754(a)(1). One of the Tier 1
default assumptions is that the NMOC concentration in the gas discharged from the landfill is
4000 parts per million by volume(ppmv)as hexane (CsH14).
The emission rate from the ACWMF exceeds the 50 Mg/yr threshold based on the Tier 1 default
value for NMOC. Therefore, ACWMF conducted Tier 2 sampling to determine the site-specific
NMOC concentration for calculation of the annual Tier 2 NMOC emissions rate.
The EPA Method 25C test result for the 12.3 hectares area with emissions not collected by the
GCCS-1 is 233 ppmv as hexane. Testing was performed by collecting 25 composite samples.
The result has been corrected for water vapor and nitrogen. This value was used in the Land
GEM emissions model for thel2.3 hectares area. Also,ACWMF reduced the annual total waste
acceptance rate used in the Land GEM emissions model by 45.1% based on the area ratio since
54.9% of the landfill is the uncontrolled portion. The model results are in Table 1.
The EPA Method 25C test result for the 10.1 hectares area controlled by GCCS-1 is 571 ppmv
as hexane. Sampling was collected at the common header with the emissions result corrected
for water vapor and nitrogen. The emissions for this area were calculated using the equation in
40 CFR 60.754(b)with an annual landfill gas(LFG)extraction flow rate of 17.416 m3/min
(615 scfm)for the next 5 years. Since the 2016 LFG extraction rate data was not available this
value has been assumed for comparison to the emissions limit. This appears to be reasonable,
since the 2015 LFG extraction rate was 11.808 m3/min(-417 scfm). Based on the 615 scfm
extraction rate and 571 ppmv as hexane the 40 CFR 60.754(b)equation indicates the GCCS-1
controlled LFG Emissions Rate is 18.79 Mg/yr.

J
Heather Carter, Fayetteville Regional Office
May 15, 2018
Page 2(Anson County Waste Management Facility-Site-Specific Tier 2 Landfill NMOC)
Table 1: 40 CFR 60 Sub art WW W-Anson C unity Waste Manage ant Facility
' Waste Input Values are Reduced Based on Area GCCS-1 Waste Area
Uncontrolled Waste Area (Test Date 11-15-16)
(Test Date 11-14.16) NMOC a 671 ppmv as
NMOC=233 ppmv as hexane hexane at 615 scfm
Estimated As of January 1 Modeled Tier 2 40 CFR 60.754(b) NMOC Total ACWMF
Emissions Annual Waste Current Solid NMOC equation Emissions Tier 2 NMOC
'i Year Acceptance Waste-in-place, Emissions, NMOC Emissions, Limit, Emissions,
Modeled Rats, M /Yr (Mg) (MglYr) (Mgfyr) (MglYr) (MgiYr) Compliance
2016 253,039' 2,014,255 228.37-
1.30" 18.79' <50 40.09 Indicated
2017 253,039' 2,287,295" 3.77 18.79 <50 42.58 Indicated
2018 263,039' 2,520,334' 6.13" 18.79 <50 44.92 Indicated
2019 253,039' 2,773,373' 18.79 <50 47.162020 253,039' 3,026,412" 0.50" %79 <50 49.29 Indicated
Assuming only waste recelpts ff9r,areas not Influenced by GCCS in years 2016 to 2020 as provided by Landfill.
Waste-in-place only for areas not influenced by GCCS in years 2016 to 2020 as provided by,Landfill.
Note:54.9%of the landfill area waste is currently uncontrolled while 45.1%is collected and controlled by GCCS-1.
Tier 2 Compliance was indicated for the ACWMF for the next 5 years based on the site-specific
NMOC concentrations and the tabulated assumptions. The site-specific NMOC concentrations
should be retested every 5 years. If the actual waste acceptance rate exceeds the estimated
waste acceptance rate in any year reported in the 5-year estimate, a revised estimate shall be
submitted to the Administrator.
If there are any questions concerning this matter, please contact me at(919)707-8415 or
arepg:oneal4ncdennoov.
cc: Booker Pullen, Air Permitting Section
Central Files,Anson County
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IBEAM Documents-0400052