AQ_F_0400052_20121005_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: 10/15/2012
Facility Data Compliance Data
Anson County Waste Management Facility Inspection Date 10/05/2012
375 Dozer Drive Inspector's Name Mitch Revels
Polkton,NC 28135 Operating Status Operating
Lat: 35d 0.2610m Long: 80d 9.7720m Compliance Code Compliance-inspection
SIC: 4953/Refuse Systems Action Code FCE
NAICS: 562212/Solid Waste Landfill On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 09835/R01
Brad Green Brad Green Nelson Breeden Issued 8/10/2012
District Manager District Manager Region Engineer Expires 7/31/2017
[phone] [phone] [phone] Classification Synthetic Minor
Permit Status Active
Inspector's Signature: Comments:
Date of Signature: I S LC l
This facility has no RICE,therefore not subject to MACT ZZZZ.
1) Location: 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: Anson County Waste Management Facility(ACWMF) is a municipal solid waste
(MSW)landfill. The MSW landfill facility is not required to have a permit as an emission source,
because 2Q .0 1 02(c)(1)(K)exempts MSW LF from air permit until Title V threshold as reached or
exceeded. ACWMF applied for a synthetic minor permit to install and operate a landfill gas capture
and control system with a candlestick flare. Therefore,ACWMF has a state air permit for the
candlestick flare.
ACWMF first accepted waste in CY 2001. During CY2012, the amount of in place waste is projected
to exceed both 2.5 million megagrams and 2.5 million cubic meters. Therefore, when these limits are
exceeded in an operational permit(PTO) issued by NC Solid Waste, the facility must apply within 90
days for a Title V air permit. Presently ACWMF has a solid waste permit to construct(PTC)for a
capacity of 4.67 mm yd3. NOTE: 1 yd3=0.7646 m3 and 1 ton=0.9072'Mg. The next issued SW
PTO will most likely trigger the TV permit requirements and NSPS WWW and MACT AAAA
requirements. The facility already has a gas collection and control system (GCCS)required by NSPS

WWW. Facility chose to install a GCCS before the required date where calculated NMOC reach 50
Mega Grams per year. This allowed them to build carbon credits and pursue a gas-to energy project.
The facility may test out per Tier 2 as outlined in NSPS WWW.
The facility performed a Tier II test and tested out of a gccs until Sept 2012. The previous inspection
was performed in conjunction with the Tier II test observation. The facility was operating around 280
cfm at 60%methane and no 02. FRO concludes that the facility was operating at optimum
conditions for Tier II sampling. On April 19, 2012,DAQ FRO issued a letter to facility approving
the Tier II sampling that was performed 15 Dec 2011. The Tier H results indicated an additional 5
year with on GCCS requirement by Air Regulations.
This facility is permitted under Air Permit No. 09835R01, effective from 10 Aug 2012,until 30 July
2017.
3) Current throughputs: Per the most recent data online indicates NC DENR MSW Annual Report FY
2008-2009,total waste in place was 2.07 million tons, with 208,982 tons disposed in FY 2007-2008.
During this inspection on 10/05/2012,the landfill gas flow rate,350 acfm, with 60% methane. This
was verified at the flare recorder located next to flare.
4) Permitted Sources are:
Emission Emission Source Control Control System
Source ID Description System ID Description
_
Municipal Solid Waste Landfill,NSPS WWW,including:
CD-1 Candlestick flare,75 mmBtu per hour maximum heat
input
Inspection Note for 5 Oct 2012: Flare was
operating at 350 acfm as recorded a verified at N/A N/A
Flare control panel. Present GCCS consist of 19
active gas wells.Methane conc.was around 55-
60%
5) Inspection Conference: On 5 Oct 2012, I,Mitchell Revels met with the Mr.Travis Ricker,Facility
Operator and Timothy Fadual,Division VP. We discussed the following:
a) Verified the contacts based on FACFI NDER printout.
b) We discussed the design capacity of the facility and the TV permit requirements when
modification of SW PTO increases to or greater than 2.5 MM cubic meters and 2.5 MM Mg.
c) We discussed that facility presently holds a state only permit with a limit of 2000 acfm to
flare and a weekly recordkeeping requirement.
d) The facility presently has a Title V permit application in RCO however Title V permit has not
been processed to date..
e) 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.Ricker and I, Mitchell Revels tour the LF. The flare was observed
operating at a flow of 350 acfm with no opacity. Mr.Ricker 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. Presently the facility holds a
permit for the flare,however when Title V,NSPS WWW and NESHAP AAAA requirement began
the facility will need to comply accordingly.
7) Stipulation Review:
a. 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.
b. VISIBLE EMISSIONS CONTROL REOUIREMENT-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 %.
15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -
Appears in Compliance. NSPS WWW not yet applicable but will likely apply at next
modification of the solid waste operational permit.
c. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints or excessive fugitive dust
emissions from the facility are observed beyond the property boundaries for six minutes in
any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or operator
may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter from process operations that does not pass
through a process stack or vent and that is generated within plant property boundaries from
activities such as: unloading and loading areas,process areas stockpiles, stock pile working,
plant parking lots, and plant roads (including access roads and haul roads).
Appears in Compliance. No dust or fugitive PM was observed leaving property. The
facility has a large buffer with no nearby neighbors. The access road is paved and the dirt
road around the actual LF is watered each day if not rainy. The total property is over 1000
acres with activity only on about 300 acres.
d. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT-Pursuant to 15A NCAC 2D .l 100 "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:
Affected Source ���Toxic Air Pollutant Emission Limit

Candlestick flare(CD-1) Hydrogen chloride(7647-01-0) 0 47 lb/hr
Appears in Compliance. Modeling was based on LANDGEM-generated flow rates and
indicated less than 7%AAL.
e. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -As required 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 DAQ has not received any odor complaints. I detected typical
landfill gas odor onsite,but not offensive. No odor was detected offsite.
f. LIMITATION TO AVOID 15A NCAC 20 .0501 -Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee,facility-wide CO
emissions shall be less than 100 TPY.
Appears in compliance The potential emissions after control are based on 2,000
cfm, as requested in the permit application. The potential emissions before control
are based on 2,500 cfm. The present LF gas flow rate was indicated to be 350 acfm.
The limit is 2000 cfm.
g. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REOUIREMENT-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 anda 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.
8) Reporting requirements:Presently no reporting is required.
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
NC Solid Waste documentation,this facility will become subject to TV after next modification to
increase capacity per a Solid Waste Permit to Operate.
Next inspection should be after extended dry weather to evaluate fugitive dust control.
11) 5 Year Compliance History: None
/mr