AQ_F_0800102_20180816_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY East Carolina Regional Solid Waste Landfill
NC Facility ID 0800102
Inspection Report County/FIPS:Bertie/015
Date: 08/17/2018
Facility Data Permit Data
East Carolina Regional Solid Waste Landfill Permit 08849/T08
1922 Republican Road Issued 10/27/2016
Aulander,NC 27805 Expires 9/30/2021
Lat: 36d 6.9563m Long: 77d 4.1832m Classification Title V
SIC: 4953/Refuse Systems Permit Status Active
NAILS: 562212/Solid Waste Landfill Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
MACT Part 63: Subpart AAAA
Matt Einsmann,P.E. Drew Isenhour Matt Einsmann,P.E. NSPS: Subpart W W W
Environmental Manager Area President Environmental Manager
[phone] [phone] [phone]
Compliance Data
Comments: The facility appeared to operate in compliance with all applicable Air
Quality regulations and permit conditions at the time of inspection. Inspection Date 08/16/2018
Inspector's Name Doug Byrd
Inspector's Signature: r Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �7�1`� On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 6.62 3.22 33.65 13.44 123.69 6.62 6088.25
2016 7.24 3.47 36.15 12.98 135.08 7.24 6656.00
2015 5.46 2.73 28.92 12.38 121.64 5.46 5015.40
*Highest HAP Emitted in 22RLdls
Five Year Violation History:None
Performed Stack Tests since last FCE:None
FACILITY LOCATION:
This facility is located on 1922 Republican Road. From WaRO take Hwy 17 to Williamston and continue on Hwy
13/17 towards Windsor. Take a left onto Rte 308 towards Drew at the stoplight just past the FORD dealership(on
right will be a convenience store). Republican Road(SSR 1225)comes up on the right within 2 miles. Follow
Republican Road for approximately 9 miles(will have to cross School Road)and the facility will be on the right.
Take note that Republican Road will veer to the left approximately 1.1 miles before the facility.
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PROCESS DESCRIPTION:
This facility is a municipal solid waste landfill owned by Republic Services of North Carolina that receives
municipal solid waste,construction/demolition debris,and non-hazardous special wastes. The landfill is lined with
a geomembrane material. Landfill gas is collected and flared.
FACILITY SUMMARY:
A second flare(CD-Flare2)was installed and became operational on August 23,2012. After the issue of T06,an
appeal was filed and a Special Order of Consent became effective on August 6, 2012. In the Review for Permit T07,
CISWI was determined to be non-applicable. Revised Permit 08849T07 was issued with an effective date of August
7,2013 and expired February 28,2017. Permit 08849T08 was issued on October 27,2016 and expires on
September 20,2021.
FACILITY SAFETY:
A safety vest is required at the facility at all times. A hardhat is required when in the landfill area.
PERMITTED SOURCES:
Emission Source ID No.r Emission Source Description Control Device ID No. Control Device Description
ES-01 Municipal solid waste landfill CD-GCCSI One landfill gas collection and
(NSPS MACT) control system
CD-Flarel One landfill gas-fired open flare
(3000 scfin maximum flow rate)
CD-Flare2 One landfill gas-fired open flare
3000 scfin maximum flow rate
Insienifleant Sources:
,yy
..$1Y381�On(SOUYCeiID� O`,l i %�' it Y L'�1nS$YOn SOLtb@,DOSCYlpt14n
IES-04 Diesel engines for miscellaneous landfill support
IES-05 Welding operations
IES-06 Diesel storage tank
IES-07 Two leachate storage tanks
INSPECTION OBSERVATIONS/RESULTS:
On August 16,2018,Samantha Mellott and I,Doug Byrd,conducted a state compliance inspection for Eastern
Carolina Regional Solid Waste Landfill. I was assisted by Mr.Michael Kavanaugh,the Division Manager at the
facility.
There are currently approximately 100 wells at the site, 18 cleanoms,three man-holes,five PV Wells,and 18 gas
well-water pumps. Mr.Einsmann indicated that no more wells will be coming online this year. The collection
system(under a negative pressure from two blowers at the flare)allows gas to migrate to the flare where it is
combusted. Underneath the fill,there is a 60 mil plastic liner that allows liquids to drain to a collection point where
it is pumped to leachate storage tanks near the flare skid. The liquid is then currently hauled by trucks to the Rocky
Mount wastewater treatment plant for disposal.
At the end of each day,the area to which fill has been added is covered with a layer of material called
"POSISHELL." This material is similar to cement without the aggregate and is used to ensure wind will not
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disperse the material which has just been deposited. Currently,the facility is permitted for approximately 23 million
cubic yards(MCY)of air space(mound height). To date, 12.8 MCY of air space have been consumed. The facility
is currently using cell 13,which is projected to last into 2018. They are currently permitted for cell 14 with Solid
Waste which is currently under construction. Cell 14 is projected to add 1.24 MCY of air space.
Mr.Kavanaugh indicated that there are currently no plans for use of the LFG and it will continue being burned off in
the flares.
During a tour of the facility during the inspection,both flares were operating. No visible emissions were observed.
The following operational parameters were observed during the inspection:
Temperature Gas Flow Rate scfin
CD-Flarel 1 1,194 2065
CD-Flarel 1 520 1500
The flares have an in-line flash arrester to keep fire from traveling back up the pipe. A propane source is used to
start the flare after it has been shutdown(until the LFG starts to flow through the isolation valve).
The facility was operating at the time of the inspection,and the equipment appeared to be well maintained. No off-
site dust,odor,or source specific visible emissions were observed.
REGULATORY REVIEW:
2D.0524,NSPS,Subpart W W W—The landfill has a design capacity of 5.9 million Mg which exceeds the
threshold of 2.5 million Mg. Therefore,the landfill must use a collection and control system. To comply with this
Rule,the facility utilizes two open flares that meet the requirements of 40 CFR 60.18(requirements pertaining to
gas flow).
When using a flare,the facility is required to operate a heat sensing device to indicate the continuous presence of a
flame. They must also operate a device that records flow to or bypass of the flare. The facility is required to maintain
a gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes, or secure
the bypass line valve in the closed position. Initial testing is required indicating that the flare meets the requirements
of 40 CFR 60.18. The facility must keep operational records of the flare for 5 years.
Operation of the flares is monitored and controlled at control panels located on the blower skid. These
control panels manage start-up and shut-down activities as well as record the flow rate and temperature of
LFG for each flare. If either flare shuts down,the control panel automatically closes the appropriate shut-off
valve,closing off all LFG flow to that flare stack,thus preventing free venting of uncombusted LFG.
At each landfill wellhead,the facility is required to measure the gauge pressure in the gas collection header,monitor
nitrogen or oxygen concentration in the landfill gas, and monitor the temperature of the landfill gas on a monthly
basis. If either a positive pressure,temperature greater than 55C(13IF),and with either percent nitrogen,greater than
20%,or percent oxygen,greater than 5%exists,then a corrective action must be initiated within 5 days and rechecked
within 15 calendar days. If the exceedance cannot be corrected within 15 days of the first measurement, the gas
collection system shall be expanded to correct the exceedance within 210 days of the initial exceedance. The facility
must keep records for at least five years of all collection and control system exceedances of the operational standards,
the reading in the subsequent month and whether or not the second reading is an exceedance,as well as the location
of each exceedance. The owner or operator may also establish a higher operating temperature,nitrogen, or oxygen
values at a particular well.
The facility keeps a logbook that contains spreadsheets of the monthly readings of the gauge pressure,temperature
and percent oxygen. The records indicate the landfill had several exceedances in the past 12 months,but it appears
actions were taken in a timely manner. The exceedances were corrected by adjusting the wellhead vacuum.
As of December 9,2011,DAQ-WaRO has allowed the facility to designate the following wells(EW-1,EW-2,EW-
3,PV-2,and PV-4)as"non-producing" (20111209-alt ops and monit ltr.doc). This designation allows the facility
to take a different set of actions when an NSPS exceedance is experienced.
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On October 10,2013,DAQ-WaRO granted the facility a{wellhead temperature variance up to 150F for 21 wells
(20 13 1010 Temperature Variance Approval.docx).
On February 10,2014,DAQ-WaRO allowed the facility to apply the temperature variance to replacement wells
2513,27B and 41B(HOV Well Replacement.txfl.
On May 5,2014,DAQ-WaRO granted the facility a wellhead temperature variance up to 150F for well EW-57
(20140501 Temperature Variance Approval.docx).
On December 5,2015,DAQ-WaRO granted the facility a wellhead temperature variance up to 150F for wells EW-
22A,EW-23A,EW-26B and EW-302. DAQ also allow the facility to apply the temperature variance to
replacement well EW-46A(20141205 Temperature Variance Approval.docx).
On February 25,2015,DAQ-WaRO granted the facility a wellhead temperature variance up to 165F for well EW-
46A(20150225 Temperature Variance Approval.doc).
On February 18,2016,DAQ-WaRO granted the facility a well head temperature variance up to 165F for wells EW-
2813,EW-40A,and EW-43A(20160218 Temperature Variance Approval.doc)and required CO monitoring of these
wells.
On June 13,2016,DAQ-WaRO granted the facility a well head temperature variance up to 165F for seven wells
(20160613 Temperature Variance Approval.doc).
On July 25,2016,DAQ-WaRO granted the facility a wellhead temperature variance up to 170F for 25 wells
(20160725 Temperature Variance Approval.doc).
On December 22,2017,DAQ WaRO granted the facility a well head temperature variance up to 150F for wells EW-
77 and EW-78. A variance up to 165F was granted for wells EW-79 and EW-309A.
(https://neconnect.sharepoint.com/sites/deg/dag waro/Shared%20Documents/ FacilitiesBertie08/00102/20171221
%o20Te=erature%20 Variance%20Approval.docx)
As of December 22,2017,the wellhead temperature variances have been granted as follows:
Granted a wellhead tem erature variance up to 150F
EW-23A EW-32A EW-53 EW-60
EW-24A EW-45 EW-55 EW-61
EW-27B EW-49 EW-56 EW-63
EW-30A EW-50 EW-57 EW-302
EW-77 EW-78
Granted a wellhead temperature variance up to 165F
EW-28B EW-40A EW-09 EW-309A
Granted a wellhead tem erature variance up to 170F
EW-7A EW-26C EW-43A EW-62
EW-11A EW-31A EW-46A EW-63A
EW-15B EW-36A EW-47 EW-68
EW-20 EW-38A EW-48 EW-73
EW-21B EW-41C EW-51A EW-303A
EW-22A EW-42B I EW-58 EW-304
EW-25C
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No other wellhead temperature variances have been applied for or granted since December 2017. Compliance is
indicated.
The facility must monitor surface concentrations of methane along the entire perimeter of the collection area and
along a pattern that traverses the landfill at 30 meter intervals(or site-specific established spacing)for each
collection area on a quarterly basis. The methane concentration must be less than 500 parts per million above
background concentrations at any surface of the landfill. If a location has an exceedance of the 500 ppm standard,
then a second reading must be taken within 10 days;otherwise a reading must be taken one month from the initial
exceedance. If an exceedance occurs again,another reading must be taken within 10 days. For any three
exceedances that occur at any location within a quarterly period,a new well or collection device must be installed
within 120 days of the initial exceedance.
I observed the records for quarterly surface monitoring of methane.The routes are explained in the design plan. The
semi-annual report covering July 1,2017 thru December 31,2017 and collection data through July 2018 have
indicated that methane exceedances have occurred during that period. Follow-up monitoring within 10 days of the
exceedance measured methane concentrations below the 500 ppm standard. Compliance is indicated.
Additional Recordkeeuine Requirements
For at least five years,the facility must keep record records of the maximum design capacity,the current amount of
solid waste in-place,and the year-by-year waste acceptance rate.
Records of control device vendor specifications shall be maintained until removal.
The facility must keep the following records for the life of the control equipment:
Data measured during the initial performance test or compliance determination, continuous records of operating
parameters, readily accessible plot map showing each existing and planned collector in the system and providing a
unique identification location label for each collector, installation date and location of all newly installed collectors,
documentation for the date of deposition, amount, and location of asbestos-containing or non-degradable waste
excluded from collection as well as any nonproductive areas excluded from production.
Records of all collection and control system exceedances of the operational standards shall be maintained for a
minimum of five years.
The facility appears to be keeping these records. Compliance is indicated.
Renortina Requirements
The facility must submit annual reports noting exceedances of wellhead parameters,periods when the LFG stream is
diverted from the flare,periods when the flare is not operating,periods when the collection system was not
operating in excess of 5 days,the location and concentration of each methane concentration exceedance,the date of
installation of each well or collection system expansion added,and a summary of all DAQ approved
decommissioned well closures and nonproductive areas.
The reports must be submitted by 30 days after each calendar half for the preceding six-month period. All instances
of deviations from the requirements must be clearly identified.
The reports are being submitted semi-annually. The last semi-annual report covering Janurary 1,2018 thru June 30,
2018 indicates compliance.
2D.0516—Sulfur Dioxide Emissions from Combustion Sources
Sulfur dioxide emissions are limited to 2.3 lbs per million Btu. The combustion of landfill gas produces negligible
sulfur dioxide emissions. Compliance is indicated.
2D.0521—Control of Visible Emissions
Visible emissions are limited to 20 percent opacity. No VE was observed during the inspection. A search of DAQ
records indicates no complaints regarding visible emissions have been received since the last inspection.
Compliance is indicated.
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2D.1806—Control and Prohibition of Odorous Emissions
The facility is required to take suitable measures to control odorous emissions. No odor was detected during
inspection. A search of DAQ records indicates no complaints regarding odorous emissions have been received
since the last inspection. Compliance is indicated.
2D.1111,40 CFR Part 63,Subpart AAAA: National Emissions Standards for Hazardous Air Pollutants,
Municipal Solid Waste Landfills
The regulation references compliance with 40 CFR Part 60,Subpart W W W and additionally requires the
implementation of a startup,shutdown and malfunction plan(SSM)that must be maintained on site. The SSM is a
corporate plan used at all Republic facilities.
A 40 CFR 63.10(d)(5)SSM report noting actions taken to minimize emissions must be submitted semi-annually,
and is due by 30 days after each calendar half. Also,immediate reports of SSMs are required within 2 days and a
letter is required within 7 days if any actions taken are not consistent with the SSM plan.
A number of startup/shutdown events did occur,most of which were due to power failures. The facility noted
compliance with the SSM plan for these events with a checklist. The SSM report is submitted with the NSPS semi-
annual report,which was most recently for the period covering January I,2018 thru June 30,2018. Compliance is
indicated.
2Q.0317—Avoidance Conditions(2D.0530 Prevention of Significant Deterioration—Carbon Monoxide)
Open flares(CD-FlareI and CD-Flare2)are limited to 250 tons of Carbon Monoxide discharged into the atmosphere
and combustion less than 2,628,000,000 113 of landfill gas per consecutive 12-month period. The Permittee shall
keep monthly records of the amount of landfill gas burned in open flares,as well as monthly carbon monoxide
emissions. A report containing the monthly carbon monoxide emissions for the previous 12 months over a 17-
month period and the monthly landfill gas flow rate quantities for each flare in the previous 17 months must be
submitted by 30 days after each calendar half for the preceding six-month period.
Thel2-month rolling sum on June 30,2018 for carbon monoxide indicated a maximum of 143.0 tons and the sum
for landfill gas combustion indicated a maximum of 144,957,467ft';both of which are below their limits.
Compliance is indicated.
2D.0535—Excess Emissions
A search of DAQ records indicates no reports regarding excess emissions have been received since the last
inspection. Compliance is indicated.
FIVE YEAR COMPLIANCE HISTORY:
No Notices of Violation(NOV's)or Notices of Deficiencies(MOD's)have been issued to the facility in the last five
years.
CONCLUSIONS.COMMENTS AND RECOMMENDATIONS:
The facility appeared to operate in compliance with all applicable Air Quality regulations and permit conditions at
the time of inspection.
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