AQ_F_0400052_20160428_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Anson County Waste Management Facility
NC Facility ID 0400052
Inspection Report County/FIPS: Anson/007
1
Date: 05/03/2016
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
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
NSPS: Subpart WWW
Tyler Fitzgerald Tyler Fitzgerald Nelson Breeden
'I District Manager District Manager Region Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/28/2016
Inspector's Name Mitch Revels
Inspector's Signature: �, �+,� Operating Status Operating
Compliance Code Compliance-inspection
/ / Action Code FCE
:Date of Signature ! — ® 6 / On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 0.6700 0.4600 2.73 2.02 14.86 0.6700 1214.08
2013 0.8100 0.5500 3.28 1.30 17.86 0.8100 766.23
*Highest HAP Emitted(in ounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
1) Location/Directions: Anson County Waste Management Facility is located at 375 Dozer Drive,near
Polkton,NC,Anson County.

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 in the town of Polkton,Anson County,North Carolina. The landfill began accepting waste in 2001.
The facility installed a voluntary gas collection and control system in order 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
capacity was less than Title V thresholds. On September 24, 2013 the facility as issued the initial Title V
permit.
The design capacity of this facility is currently greater than the NSPS, Subpart W W W, applicability threshold of
2.5 million cubic meters by volume and 2.5 million mega grams by mass. The facility performed Tier 2 testing
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 H results indicated an additional
5 year, with no GCCS requirement by Air Regulations NSPS W W W thru 2016. At that,time facility may
choose to perform additional test to defer a required GCCS.
4) Current throughputs: The facility is currently accepting MSW at an average rate of 2000 TPD. This is
relatively low, some larger MSW Landfills accept 3000 to 5000 TPD. The average LF Gas Flow rate was
recorded at 450 scfm 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 800 cfm with around 20 Mega grams/yr.NMOC's for 2016.
5) Current Permitted Emission Sources.
N �xz �
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 450 heat input @ 500
scfm LF G on Btu/ft3 heat rate of
inspection date. I landfill gas)
*Voluntary gas collection and control system (not yet required by 40 CFR 60,Subpart W W W)
6) Inspection Conference: On 28 April 2016,I, Mitchell Revels,NC DAQ FRO met with Tyler =
Fitzgerald,District Manager,J. T.Lessor,Assistant District Manager and Nelson Breeden,Eastern
Region Engineer for an Air Quality TV permit inspection. This inspection was performed in
conjunction with Mike Lawyer,Melissa Joyner, and Tim LaBounty with the NC DEMLR FRO. The
people with NC DEMLR performed inspects for Storm Water and Erosion Control permits. 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 how that the next tier 2 test result will determine the next step for this facility in respect
to NSPS W W W. The DEMLR staff discussed the erosion control and storm water permits. The
following points were discussed:
a) Verified the contacts based on FACFINDER printout. Changes were made and have been
updated in MEAM.
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 around 2000 TPD
and remarked that as a good rate for the facility.
d) The upcoming Tier II test and that the total waste mass representation during this test. The
consultant, Juene Franklin has already began to prepare testing protocol for submittal to
DAQ.
e) We discussed that requirement for a design plan should the facility not be able to test below
50 mega gram of NMOC.
f) The present GCCS installed voluntarily before required by NSPS W W W.
7) Inspection Summary: The flare was observed operating at a flow of 450 scfin with no opacity. Mr.
Jones indicated that the control system is engineered to close and not vent to atmosphere(bypassing
control device) during flare downtime. This was verified by observing the physical design of the
system(no bypass vent and 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 414 scfm. I indicated that when the GCCS is required by NSPS,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 NOMC. Note: The
Anson County Waste Management Facility has tested-out of the required GCCS thru 2016.
8) Stipulation Review for Section 2- Specific Limitations and Conditions:
A. 15A NCAC 2D .0524,40 CFR Part 60, Subpart W W W:New Source Performance
Standards For Municipal Solid Waste Landfills
APPEARS IN COMPLIANCE:
This facility is subject to NSPS W W W, however in December 2011,the facility performed a
Tier 2 Test as outlined in 60.754 that deferred the requirement of a GCCS. DAQ approved
the test on April 19. 2012. The calculated NMOC emissions report indicated that the facility
would not be required to install an engineered GCCS before 2016. The facility submitted a 5-
year report demonstrating compliance.Therefore, an annual report is not required. The
calculated NMOC for the fifth year in 2016 is 20.69 Mg(yr.NMOC at a flow rate of 800
scfm. The facility is required to evaluate or re-test late 2016 to demonstrate when the NMOC
will exceed 50 Mg/yr. When 50 Mg/yr. of NMOC is exceeded,the facility will no longer
have a volunteer GCCS and will be required to meet the additional requirement of NSPS
W W W, like monitoring the gas well, surface scans,and gas well expansion every five year at
minimum. Presently the facility has a voluntarily GCCS consisting of 25 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.

Appears in Compliance-The Tier 2 test approved April 2013 indicates that the facility
is not required to have an engineered gccs to comply with NSPS W W W before 2016.
Therefore,compliance is indicated.
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.
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 2D .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
Landfill(ES-1) Benzene 63.55 lbs/yr
Fugitive emissions Hydrogen chloride -------------
H drogen sulfide 1.84 lbs/da
WME Vinyl chloride 56.34 lb!/ r
Candlestick flare(CD-1) Benzene 3.8 lbs/ r
Hydrogen chloride 0.591bs/hr
Hydrogen sulfide 0.111
Vinyl chloride 4.51 lbs/yr
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 t
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.
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
below the AAL based on 2000 cfm burned. Therefore, under normal operation, around 450
cfm this MSW landfill cannot be 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: Annual Compliance Certification and Semi-annual report to
summarize the recordkeeping and monitoring is due July 30, 2016.
Appear In Compliance-All past reports have been received and reviewed with no deviations.
10) 112R Status: Typical MSW landfill does not use or store chemical compounds subject to
requirement for a written RMP
11) Non-Compliance History Since 2010:None
12) Comments and Compliance Statement: Facility appears in compliance based on inspection
and NSPS W W W Tier 2 test approved April 2013. Closely evaluate the source test protocol
when submitted to performed Tier II test around December of 2016 to determine the acceptable
method and calculation as outlined in NSPS WWW.
PINK SHEET ADDITIONS: None.
/mr