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HomeMy WebLinkAboutAQ_F_0400052_20131017_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: 10/28/2013 Facility Data Permit Data Anson County Waste Management Facility Permit 09835/T02 375 Dozer Drive Issued 9/24/2013 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 (704)694-6900 (704)694-6900 (865)200-7650 Compliance Data Comments: Inspection Date 10/17/2013 � p Inspector's Name Mitch Revels Inspector's Signature: M � p w v'C/ Operating Status Operating G1 � Compliance Code Compliance-inspection d 1 Action Code FCE Date of Signature: ocy CJ !3 On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *IIAP 2011 0.80, 0.60 1.80 3.30 33.50 0.80 1269.00 *Hi hest HAP Emitted(inpounds) Five Year Violation History: None Performed Stack Tests since last FCE: None 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 thm 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 1400-1500 TPD. This is relatively low, some larger MSW Landfills accept 3000 to 4000 TPD. The average LF Gas Flow rate was recorded at 350 cfm during this inspection. That was about the same flow when the facility tested out of a required GCCS in December 2011. 4) Current Permitted Emission Sources. i Emission'Source ID Emission Source Description Control Device Contrdl System Description ID_ ES-1 One municipal solid waste landfill GCCS-1 * Gas collection and control NSPS Subpart W W W system Accepting 1400-1500 TPD CD-1 * Candle stick type flare(2500 scfm,75 million Btu per Collecting and hour heat input @ 500 flaring around 350 Btu/ft3 heat rate of landfill cfm LF Gas gas) *Voluntary gas collection and control system(not yet required by 40 CFR 60,Subpart W W W) 5) Inspection Conference: On 17 Oct 2013, I,Mitchell Revels met with the Mr.David Jones,Facility Operator. He indicated that he had been at this facility since around February 2013. We discussed the following: a) Verified the contacts based on FACFINDER printout. b) We discussed that the facility had been recently, as of Sept 2013, issued the initial TV permit. I indicated that he should review that permit and contact me if he has any questions or comment. He stated that he plans to review and complete a calendar program to notify him of the appropriate compliance requirements contained in this permit. c) We discussed the waste acceptance rate. d) The facility presently has 19 operating gas extraction wells,4 leachate clean headers and an average acceptance rate of 800 TPD. 6) Inspection Summary: Mr. Jones and I,Mitchell Revels tour the LF. The flare was observed operating at a flow of 350 acfm 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 350 acfm. 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. 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 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/vr 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/vr. When 50 My/3T 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 summary report of the monitoring and recordkeeping activities by Jan. 30, 2014. Appears in Compliance- The Tier 2 test approved April 2013 indicates that the facility is in compliance. This condition will be re-evaluated each year during compliance inspection of the facility. b. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 213 .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 Affected Source Toxic Air Pollutant I Emission Limit l Candlestick flare(CD-1) Hydrogen chloride(7647 01-0) 0.471b/hr Appears in Compliance. Modeling was based on LANDGEM-generated flow rates and indicated less than 7% AAL. e. 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,HCL emission is about 6.7 %of AAL based on 2000 cfm burned. Therefore,under normal operation, around 400 cfm this MSW landfill cannot be exceed Toxic limits. S) Reporting requirements: Semi-annually to summarize the recordkeeping and monitoring activities will begin 7an.2014. 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. 11) 5 Year Compliance History: None /mr