AQ_F_0400052_20150106_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
Date: 01/07/2015
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
David Jones David Jones Nelson Breeden NSPS: Subpart W W W
District Manager District Manager Region Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 01/06/2015
Inspector's Name Mitch Revels
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: .-- I On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 0.8100 0.5500 3.28 1.30 17.86 0.8100 766.23
2011 0.8000 0.6000 1.80 3.30 33.50 0.8000 1269.00
*Highest HAP Emitted(in pounds)
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.
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.
2) 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 WWW, applicability
threshold of 2.5 million cubic meters by volume and 2.5 million megagrams by mass. The facility
performed Tier 2 testing on December 15, 2011 and the results indicated that the NMOC emissions
were below 50 megagrams per year (threshold to require a mandatory gas collection and control
system). The Tier II results indicated an additional 5 year, with no GCCS requirement by Air
Regulations NSPS W W W thru 2017. At that time facility may chose to perform additional test to
further defer a required GCCS.
3) 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 400 scfm during this inspection. That is little more flow than when the
facility tested out of a required GCCS in December 2011.
4) Current Permitted Emission Sources.
Emission'Source ID Emission Source Description Control Device Control System Description;'
ID
ES-1 One municipal solid waste landfill GCCS-1 * Gas collection and control
NSPS Subpart W W W system
Waste Acceptance Rate of an
annual average of 2000 TPD CD-1 * Candle stick type flare(2500
scfm,75 million Btu per
Collecting and hour heat input @ 500
Haring around 414 Btu/fO heat rate of landfill
scfm LF G on gas)
inspection date.
*Voluntary gas collection and control system(not yet required by 40 CFR 60,Subpart W W W)
5) Inspection Conference: On 6 Jan 2015, I,Mitchell Revels met with the Mr. David Jones,District
Manager and Mr.J.T.Leasor, Assistant District Manager. Mr.Jones indicated that he had been at
this facility since around February 2013 and Mr. Leasor has been there for about 6 months in a
training program. We discussed the following:
a) Verified the contacts based on FACF1 NDER printout.
b) We discussed the TV permit. I asked if they had any question about the permit. Mr.Jones
indicated that he had no questions.

c) We discussed the waste acceptance rate. Mr.Jones indicated the rate is around 2000 TPD and
remarked that as a good rate for the facility.
d) I stress that one of the primary focus during this inspection was the area of the landfill with
the newest waste(placed after the Tier II test was performed in 2011)to observed the number
on gas wells installed in that particular waste mass. I indicated that I needed to get a better
understanding in preparation of the upcoming test date in 12/2016.
e) We discussed to possibility for a gas-to-energy project. It appears that the facility is
considering another type project to bum incoming waste and supply heat to nearby green
houses. I indicated that such project may be subject to EPA CISWI and that rule is very
complex.
f) The facility will send a site diagram showing location of existing gas extraction wells and
other documents as requesting during inspection.
6) Inspection Summary: Mr. Jones and Mr.Leasor and I,Mitchell Revels tour the LF. The LF
appeared to have a significant area of waste that has been placed in the past 3 year without many gas
wells installed in that waste mass. I indicated to Mr.Jones that when the facility performs additional
Tier II test this situation need to be evaluated before submitting the test protocol. The facility may
elect to install additional gas well before next Tier II testing during December 2016. The flare was
observed operating at a flow of 414 scfm 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 Count
Management Facility has tested-out of the required GCCS thru 2016.
7) Stipulation Review for Section 2- Specific Limitations and Conditions:
A. 15A NCAC 2D .0524, 40 CFR Part 60, Subpart WWW: New Source Performance
Standards For Municipal Solid Waste Landfills
APPEARS IN COMPLIANCE:
This facility is subject to NSPS WWW,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 will 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 after 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 WWW, like
monitoring the gas well, surface scans, and gas well expansion every five year at
minimum. Presently the facility has a volunteer GCCS consisting of 19 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 by Jan. 30, 2015.
Since the facility is not subject to gas well and surface monitoring, because they
tested out of a required gccs, the mentioned report should indicate if any deviation
exist.
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 WWW
before 2016. Therefore,compliance is indicated. This condition will be re-
evaluated each year during compliance inspection of the facility.
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. However,
sources which must comply with 15A NCAC 2D .0524 'New Source Performance
Standards" or.1110 'National Emission Standards for Hazardous Air Pollutants" must
comply with applicable visible emissions requirements contained therein.
Appears in Compliance. Opacity from the flare was 0 %.
D. CONTROL OF ODOROUS EMISSIONS—As require by 15A NCAC 2D .1806: The
Pernuttee 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
e- 3 t7e cri,tian Toxic:Air)pllutant�. Emission Limit
Landfill(ES-1) Benzene 63.55lbs/yr
Fugitive emissions Hydrogen chloride
H drogen sulfide 1.84 lbs/day
Vinyl chloride 56.341bs/ r
Candlestick flare(CD-1) I Benzene 3.8 lbs/yr
Hydrogen chloride 0.59 lbs/hr
Hydrogen sulfide 0.11 lbs/day

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.
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 400 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 Megagrams 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.
8) Reporting requirements: Semi-annually to summarize the recordkeeping and monitoring
activities began Jan.2014. Next report is due January 30, 2015.
9) 112R Status: Typical MSW landfill does not use or store chemical compounds subject to
requirement for a written RMP.
10) 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 W W W.
11) 5 Year Compliance History: None
/mr