AQ_F_0400052_20171024_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Anson County Waste Management Facility
NC Facility ID 0400052
Inspection Report County/FIPS:Anson/007
Date: 10/25/2017
Facility Data Permit Data
Anson County Waste Management Facility Permit 09835/T03
375 Dozer Drive Issued 8/22/2014
Polkton,NC 28135 Expires 8/31/2018
Lat: 35d 0.2610m Long: 80d 9.7720m Classification Title V
SIC: 4953/Refuse Systems Permit Status Active
NAICS: 562212/Solid Waste Landfill Current Permit Application(s)None
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Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
i Tyler Fitzgerald Tyler Fitzgerald Nelson Breeden
NSPS: Subpart WWW
District Manager District Manager Region Engineer
F [phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 10/24/2017
Inspector's Name Mitch Revels
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
( � —7 Action Code FCE
Date of Signature: Q � L 2�� Z0 1 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
E' TSP­ S02 NOX VOC CO PM10 *HAP
P
2016 0.9900 0.6700 4.03 2.35 21.91 0.9900 1413.25
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2015 0.8000 0.5500 3.27. 2.38 17.77 0.8000 1373.55
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2014 0.6700 0.4600 2.73 2.02 14.86 0.6700 1214.08
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*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
I
Performed Stack Tests since last FCE:
f Date Test Results Test Method(s) Source(s)Tested
11/15/2016 Pending
1) Location/Directions: Anson County Waste Management Facility is located at 375 Dozer Drive,near
t Polkton,NC,Anson County.
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Directions: From FRO,take Raeford Road,Hwy 401, south to Wagram,—32 miles. Just past Wagram,turn
right onto Old Wire Road(SR 144)to Laurel Hill. Turn right(west)on Highway 74 and go approx. 41 miles.
Turn right between NC DMV office building and bridge over Brown Creek. Go approx. 0.4 mile and the
landfill office is on the right.
2) Safety: Helmet, safety boots and safety vest is required when near the working face of the landfill. The
principal hazards are from truck traffic and falls/sprains from walking on the uneven ground.
3) Description: The Anson Waste Management Facility(AWMF)is a municipal solid waste(MSW)landfill
located near the town of Polkton,Anson County,North Carolina. The landfill began accepting waste in 2001.
The facility installed a voluntarygas collection and control system to control odor,to minimize landfill gas
migration,to allow the facility to build carbon credits,and to pursue gas-to-energy projects. The initial Air
Quality permit was a state issued Synthetic Minor Permit for a waste gas flare because at that time the design j
capacity was less than Title V thresholds. On September 24,2013,the facility was issued the initial Title V j
permit.
The design capacity of this facility is currently greater than the NSPS, Subpart WWW, applicability threshold of
2.5 million cubic meters by volume and 2.5 million mega grams by mass. The facility performed Tier 2 testing 1
on December 15,2011 and the results indicated that the NMOC emissions were below 50 mega grams per year
(threshold to require a mandatory gas collection and control system). The Tier II results indicated an additional
5 years,with no GCCS requirement by Air Regulations NSPS WWW thru 2016. This facility performed
another Tier II test in November 2016 and submitted a test report on December 15,2016. The data summary of
that report indicates the,facility continues to test out, less than 50 Mg/yr.NMOC until 2020. The test is pending
approval by SSCB in Raleigh Central Office,
4) Current throughputs: The.facility is_currently accepting MSW at an average rate of 2400 TPD. This is
relatively low, some larger MSW Landfills accept 3000 to 6000 TPD. The average LF Gas Flow rate was
recorded at 500 scfin during this inspection. That is little more flow than when the facility tested out of a
required GCCS in December 2011. The projected NMOC concentration calculation contained in the Tier 2 test
was based on a flow of around 616 scfm with around 40 Mega grams/yr.NMOC's for 2016.
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5) Current Permitted Emission Sources.
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ES-1 One municipal solid waste GCCS-1 * Gas collection and
NSPS Subpart WWW landfill control system
Waste Acceptance Rate of an CD-1 * Candle stick type flare
annual average of 2000 TPD (2500 scfm, 75
Collecting and million Btu per hour
flaring around 500 heat input @ 500
scfm LF G on Btu/ft3 heat rate of
inspection date. landfill gao
* Voluntary gas collection and control system (not yet required by 40 CFR 60,Subpart WWW)
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6) Inspection Conference: On 24 October 2017,I,Mitchell Revels,NC DAQ FRO met with Tyler
Fitzgerald,District Manager,for an Air Quality TV permit inspection. Presently the Air Quality
permit is relative simple until this facility grows to the point where they can no longer test out of the
requirements of needing a Design Plan for an engineered GCCS. This was_discussed in the meeting_
e

how that the 2016 NSPS WWW Tier Il--test result will determine the next step for this facility in
respect to NSPS WWW. That test approval is pending review by SSC RCO. The following points
were discussed:
a) Verified the contacts based on FACFINDER printout. Changes were made and have been
updated in IBEAM.
b) We discussed the TV permit. I asked if they had any question about the permit. Mr.
Fitzgerald indicated that he had no questions.
c) We discussed the waste acceptance rate. Mr. Fitzgerald indicated the rate is up around 2400
TPD and remarked that as a good rate for the facility.
d) We discussed that requirement for a design plan should the facility not be able to test below
50 mega grams of NMOC.
e) The present GCCS installed voluntarily before required by NSPS WWW.
f) The facility plans to install 5 new gas wells in the next 12 months.
7) Inspection Summary: Mr.Fitzgerald stated that the flare operates approximately with a flow of 475
scfm with no opacity. Mr.Fitzgerald indicated that the control system is engineered to close and not
vent to atmosphere during flare downtime. This was verified by observing the physical design of the
system(no bypass vent and the presences of auto shut-off valve). The wellheads appeared to be well
maintained and no LF gas odor was detected,a good indication of no leaks. The LF flow recorder
was observed and recording around 500 scfm. I indicated that when the GCCS is required by NSPS,
E the complete system will need to meet all requirements and gas flow recording is included as a
requirement. This facility will also be subject to NESHAP AAAA when it surpasses the 50 Mg/year
t NMOC. Note: The Anson County Waste Management Facility has tested-out of the required GCCS
thru 2016 and the pending report indicated the same through 2020.
8) Stipulation Review for Section 2- Specific Limitations and Conditions:
A. 15A NCAC 2D .0524,40 CFR Part 60, Subpart WWW:New Source Performance
C Standards for Municipal Solid Waste Landfills
APPEARS IN COMPLIANCE:
This facility is subject to NSPS WWW,however in November 2016,the facility performed a
4 Tier 2 Test as outlined in 60.754 that deferred the requirement of a GCCS. The calculated
NMOC emissions report indicated that the facility would not be required to install an
k engineered GCCS before 2020. The facility submitted a 5-year report demonstrating
compliance. Therefore,an annual report is not required. The calculated NMOC for the fifth
year in 2020 is 49.28 Mg6g.NMOC at a flow rate of 615 scfm. When 50 Mg6g. of NMOC
is exceeded,the facility will no longer have a volunteer GCCS and will be required to meet
the additional requirement of NSPS Standard for MSW Landfills, like monitoringthe a gas
well,surface scans,and gas well expansion every five year at minimum. Presently the
facility has a voluntarily GCCS consisting of 35 gas wells and 4 leachate cleanout headers
routed to the flare.
The facility is required to submit a semiannual summary report of the monitoring and
recordkeeping activities and indicate if there are any deviation. All reports have been
received with no deviations indicated.
} The November 2016 Tier 2 test is pending approved by SSCB to determine if the
Landfill is not required to have GCCS. Other than this pending test review,if appears
the Landfill is in compliance with NSPS WWW.

B. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from Flare
(ID No. CD-1)shall not exceed 2.3 pounds per million Btu heat input.
Appears in Compliance. The AP42 emission factor for flare combustion of MSW landfill
gas is equivalent to natural gas at 0.006 lbs./mmBtu which is much less than required SO2
limit.
C. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521
"Control of Visible Emissions,"visible emissions from Flare(ID No. CD-1), manufactured
after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute
period,except that six-minute periods averaging not more than 87 percent opacity may occur
not more than once in any hour nor more than four times in any 24-hour period.
Appears in Compliance. Opacity from the flare was 0%.
D. CONTROL OF ODOROUS EMISSIONS—As require by 15A NCAC 2D .1806:The
Permittee shall not operate the facility without implementing management practices or
installing and operating odor control equipment sufficient to prevent odorous emissions from
the facility from causing or contributing to objectionable odors beyond the facility's boundary
Appears in compliance. The facility has no odor complainant nor has odor been notice
beyond the property lines.
E. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING -
REQUIREMENT-Pursuant to 15A NCAC 213 .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration,the
following permit limits shall not be exceeded:
Projected emission rates through landfill closure in the year 2044
NINK
Landfill(ES-1) Benzene 63.55 lbs/ r
Fugitive emissions Hydrogen chloride -------------
Hydrogen sulfide 1.84 lbs/da
Vinyl chloride 56.34 lbs/ r
Candlestick flare(CD-1) Benzene 3.8 lbs/ r
Hydrogen chloride 0.59 lbs/hr
Hydrogen sulfide 0.11 lbs/da
Vinyl chloride 4.51 lbs/ r
Appears in Compliance. Modeling was based on LANDGEM-generated flow rates and
indicated less than 7%AAL.
F. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-Pursuant to 15A
NCAC 2Q .0711 "Emission Rates Requiring a Permit,"for each of the below listed toxic air
pollutants(TAPS),the Permittee has made a demonstration that facility-wide actual emissions _
do not exceed the Toxic Permit Emission Rates(TPERs)listed in 15A NCAC 2Q .0711. The
facility shall be operated and maintained in such a manner that emissions of any listed TAPs -
from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC
2Q .0711.

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The Permittee shall maintain records of operational information demonstrating that the TAP
emissions do not exceed the TPERs as listed below:
- Appears in Compliance. Per the permit review and Toxic evaluated in 2007 and revised
2014,HCL,Benzene, Hydrogen sulfide,and Vinyl chloride emission were modeled well
r below the AAL based on a LFG flow rate of 2000 cfm burned. Therefore,under normal
operation, around 450 to 500 scfm,this MSW landfill will not exceed Toxic limits. This
facility will become subject to NESHAP AAAA when the facility came no longer test out of
50 Mega grams of NMOC. Based on present regulatory requirement this facility will then on
longer be subject to NC State Toxics because it will be regulated by a federal NESHAP rule.
9) Reporting requirements: General Condition P-Compliance certification requires annual
j submittal of compliance certification report,due by March 1 of each year.
t.
h Appear in Compliance-The recent ACC was received on January 30,2017 and has been
reviewed and approved by DAQ FRO. All reports have been received by due date of March 1 of
each year and reviewed with no deviations.
10) 112R Status: Anson County Waste Landfill does not store chemical compounds subject to
requirement for a written RMP
11) Non-Compliance History Since 2010:None
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12) Comments and Compliance Statement: Anson County Waste Management facility appears in
compliance based on inspection and the data summary contained in the NSPS WWW Tier 2
performed on November 2016. This test is pending approval.
PINK SHEET ADDITIONS: None.
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