Loading...
HomeMy WebLinkAboutAQ_F_0400052_20111215_ST_STO-Rpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Anson County Waste Management Facility NC Facility ID 0400052 Stack Test Observation Report County/FIPS: Anson/007 Date: 12/20/2011 Facility Data Compliance Data Anson County Waste Management Facility Observation Date. 12/15/2011 375 Allied Rd Observer's Name Mitch Revels Polkton,NC 28135 Operating Status Operating Lat: 35d 0.2610m Long: 80d 9.7720m Action Code 23/STACK TEST SIC: 4953/Refuse Systems OBSERVED NAICS: 562212/Solid Waste Landfill Contact Data Permit Data Facility Contact Authorized Contact Technical Contact Permit 09835/R00 J.Fitzgerald J.Fitzgerald Kurt Shaner Issued 10/30/2007 District Manager District Manager Regional Engineering Expires 9/30/2012 (704)694-6900 (704)694-6900 Manager Classification Synthetic Minor (901)259-8249 Permit Status Active Inspector's Signature: Comments: Tracking Number - 2011-224ST Date of Signature: 1. 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 onto Dozer Drive just after the NC DMV office building,but before the bridge over Brown Creek. Go approx 0.4 mile down Dozer Drive and the landfill office is on the right. 2. SAFETY: The facility requires basic safety equipment, safety shoes and eye protection.A safety vest is needed in some areas where large motor vehicles are active;however DAQ inspectors can do inspection with entering these areas on foot. 3. FACILITY DESCRIPTION: The Anson County Waste Management Facility is a regional municipal solid waste (MSW) landfill. The facility is currently permitted, with a flare as the only source. The facility has an operating landfill gas collection and control system (GCCS) which is not required yet by NSPS WWW. In 2009 the facility performed a Tier II sampling and tested out of the GCCS requirement. 4. NCAC 2D .2600 requires that source testing requires a protocol submittal to DAQ prior to the test and a 15-day test date notification to DAQ to allow observation. The protocol was received at DAQ on 31 October 2011, and approved by DAQ Stationary Source Compliance Branch (David Hughes) by letter dated 29 November. The target test date was not given. The 15-day notification was received by DAQ on 30 November 2011, exactly 15 days prior to the 15 December test. 5. PURPOSE OF SOURCE TESTING: The facility has elected to perform an additional Tier II test (EPA Methods 25C and 3C) in an effort to extend the time for officially avoiding the regulatory requirements. However, if this test shows a gas concentration resulting in NMOC emissions (uncontrolled) greater than 50 Mg/year,the facility is required to submit a GCCS design plan with PE Seal by 22 Sep12. 6. STACK TEST OBSERVATIONS: On 15 December 2011, I, Mitchell Revels of the Fayetteville Regional Office, arrived at the facility at 09:30 AM to observe the Tier II source test. On site, I met Tyler Fitzgerald, District Facility Manager. Mr. Fitzgerald escorted me to the flare where Mr. Don Chastain, Chastain Env. Services prepared to do the sampling. Also on site were William Melton, AWM and Chris David, RPH. Mr. David performed a methane surface scan (for leaks) while Mr. Chastain sampled the gas collected by the GCCS. The flow averaged about 280 cfm with a very good methane cone. around 60%. At the methane concentration around 60 %, at 280 cfm the system was likely set at optimum conditions for this test. The sampling involved obtaining 4 canisters of landfill gas from a sample port just before the "knockout pot." The protocol stated that the target flow rate was between 250 and 2500 CFM. The surface scan for gas leakage showed only one methane hit of around 350 ppm. The NSPS WWW limit for an action is greater than 500 ppm. . 7. COMPLIANCE STATEMENT: Based on the protocol, the advance notification date and the observed test methods, the sampling appears to have been done in compliance with all requirements. The test results will determine follow-on actions regarding NSPS WWW compliance. cc: FRO Facility Files DAQ SSCB C ,A ._ Riley, Park, Hayden & Associates, Inc. INIR 2600 South Loop West,Ste.320 Telephone: (713)333-0444 Houston,Texas 77054 Fax: (713)333-0445 November 30, 2011 Mitchell Revels Chemist—Air Quality Division North Carolina Department of Environment and Natural Resources 225 Green Street#714 Fayetteville,NC 28301 RE: Anson Waste Management Facility Tier 2 Retest 15-Day Notification Chambers Development of North Carolina,Inc. Existing Title V Permit No. 0935ROO Facility ID No. 0400052 Dear Mr. Revels: On behalf of Chambers Development of North Carolina, Inc., Riley,Park, Hayden, and Associates, Inc. (RPH) is pleased to submit Anson Waste Management's 15-day notice to the North Carolina Department of Environment and Natural Resources(NCDENR)pursuant to the air quality regulations 15A NCAC 2D.2600. Weather permitting; RPH will conduct sampling on December 15, 2011 in accordance with sampling protocol located in Appendix A of this document. We have also included the NCDENR sampling protocol Tier 2 test approval letter located in Appendix B. Approximate sample start time will be 10:00 AM. We will notify NCDENR as soon as practically possible if weather conditions or other events necessitate the need to change the sampling date. Please feel free to call Nelson Breeden at (865) 200-7650 or me at (832) 244-1980 if you have any questions or require additional information regarding AWM's 15-day Tier 2 testing notification. Sincerely, Riley,Park, �H' Hayden, and Associates,Inc. �'W u t" Juene Franklin,PE Branch Manager Enclosures: Appendix A: AWM Tier 2 Test NCDENR Protocol Submittal Form(Rev. 201 Oa) Appendix B: AWM Tier 2 Test NCDENR Approval Letter cc: w/attachments AWM Permanent Operating Record(POR) Kurt Shaner—Waste Connections,Inc. Eastern Regional Engineering Manager Nelson Breeden—Waste Connections, Inc. Eastern Region Engineer CELEBRATING 0VER 40 YEARS OF QUALITY SERVICE APPENDIX A AWM Tier 2 Test NCDENR Protocol Submittal Form (Rev. 2010a) PROTOCOL SUBMITTAL FORM (Rev. 2010a) MCDENR DIvisioN OF AIR QUALITY PAGE I OF Purpose: The goals of kite Protocol Submittal Porto are to initiate communication between representatives of the permitted facility, the testing consultants, and die DAQ as well as to identify and resolve any specific testing concerns prior to testing. Instructions: Use Guidance Document to rill out this form. Submit all forms and additional information to the i)AO Regional Supervisor at least 45 days prior to testing. Complete one form for each sampling location. If this form does not supply sufficient space to completely answer all questions or if additional relevant Information is necessary, attach additional documentation anti/or information to lte original form. Questions and/or comments should be directed to the appropriate Regional Supervisor. This form and its Guidance Document are available from the DAQ website(littp://(Iaq.statc.iic.us/enf/sourcetestf) Specify Appropriate Regional Office: (check one) ❑ Asheville ® Fayetteville ❑Mooresville ❑Raleigh ❑ Washington ❑ Wilmington © Winston-Salem Facility Nanic:Anson Waste Management Facility Testing Company: Riley,Park,Hayden,and Associates,Inc. Facility 11)No: Facility Contact Person/mailing address&email: Testing Company Contact Person/mailing address&email: Anson County Landfill Riley, Park, I layden,and Associates. Inc. 375 Dozcr Drive 2600 South hoop West,State 320 Poikton,NC 28135 Houston,Texas 77054 Anson County Juene Franklin Tyler Fitzgerald Branch Manager Email Address: TylerF@WasteConnections.com Email Address:jfianklin@rphenginecring.com Phone:704-694-6900 Fax: 704-694-2537 Phone: (713)3 3 3-0114 4 Fax:(713)333-0445 Mobile No.: 704-966-7562 Mobile No.:(832)244-1980 Air Pert-nit Number& Revision: 09835R00-Application No. Permitted Source Name and ID No.: Candlestick Flare,CD-I 0400052.10A Permitted Maximum Process Rate: Maximurn normal Operation Process Rare: Target Process Rate for Testing: 2,500 scfrn 373 scfm 250-2,500 sctin 1.1) What is dre 5pgrifie purpose for the proposed testing?(permit condition,NSPS,NEST IAP,etc, see guidance doc): Conduct Tier 2 retest to determine NMOC generation rate(Mir-,./yr). is this an initial performance test'? ❑ Yes or ® No 1.2)List all state and federal regulations that apply to the proposed testing(see guidance doc):40 CFR 60.754(a)&(b) 13)Will the test results be used for other regulatory purposes(e.g.,emission inventories,permit application,etc.)beyond that stated above? ❑ Yes or 0 No If yes, explain. 1.4)How will production/process&control device data be documented during testing(list specific control equipment,process parameters, instrumentation that will be used, frequency of data collection,collected by computer/manually,etc.)?TEST WILL NOT BE. ACCEPTED WITHOUT APPROPRIATE PRODIJCTIONtPROCFSS&CONTROL DEVICE OPERATION DATA. All field testing process data will be documented on field logs and submitted with an Additional Tier 2 Retest report alter analytical data is received fro in Air Technology Laboratory. 1.5) Provide a brief description of the source(including control equipment)and attach source or process flow diagram from source through stack exit:Anson is a non-hazardous solid waste facility. Biodegradation of waste mass produces landfill gas(LFG)as a by-product. Blowers induce a vacuum on gas extraction wells that extracts LFG from the waste mass through a HDPE piping network. The collected LFG is then burned at the flare. A process now diagram is included in Appendix E of this document. 1.6) Provide a brief description of the sampling location,attach schematic of sampling location, and indicate whether concurrent testing will be conducted at other sampling locations(Approval of protocol without this data will not exempt you from Method I criteria): Three gas samples will be collected from the header pipe before the gas moving equipement(blowers) or condensate removal equipment(Knock-out Pot). A site plan is included in Appendix D and a typical flare skid schematic of sample port location is included in Appendix F of this document. PROTOCOL SUBMITTAL FORM (Rev. 2010a) DEER DMSION OF All(QUALITY PAGE 2 or2 ?.1)provide the following information for each test parameter. - Target I 'oposed Number of Test Run of SUMPHng comruetlls Pollutant T`estMetltod TcStRuns i7uration points nta n/a- Tier 2 Report show NMOC calculations NI MOC 2SC 3C EPA Methods Collect 3 t rlssmpl Appmx 1 i completed as outlined in 40 CFR samples e 60154(b) _ f I i 2.2) Will all testing be conducted in strict accordance with the applicable test ruethody2 If answer is❑o,abaci 0 Yes D No complete documentation of all modifications author deviations to tire applicable test methods. 2.3) Does the proposed sampling location meet the tnuo nwn E Method I criteria for acceptable measurement sites? Yes ONO AUraoh supporting documentation. 2.4) Has cyclonic flow been documented at ibis source(EPA Method I Section I I AY? 0 Yes ONO ABSENCE Or, CYCI.ON[C FIX)W MUST BE VERIFIED DIURING CURRENT TESTiNC. 2.5) will the oxygen concen ration be determined by EPA Nl.othad 3 via Orsat or[]m ict EPA Method:tA 1 0 t es El Na (specify)If answer is no,see Question 2.2 above.(1,yrites are I C)17 allowed per'15A.NCAC 2).2di06) 2.6) Do ally of the proposed test methods require analysis of FPA audit samples! if yes,not Regional Office G7 Yea 0 No a arhrimtmn of45 days prior to testing to allow for audit sample preparation and shipment. 2.7) Has all testing equipment been calibrated within the past year? If answer is no,explain. l xl Yus n No 2.8a)Have all calibration gases been certified by EPA Protocol I proceduos?(Answer only as applicable) [J Yes No 2.8b)Is a dilution system(via EPA Method 205)proposed?(Answer only as applicable) Gl Yes 0 No 2.8c) Attach a summary of expected calibration gas concentrations for ail proposod instri mental test methods. 29) What is Proposed test schedule'?DAQ Regional Snnervism'must be notified a minimum of 15 days ntior to the actual test d to s} TitIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION December 2011 Additional Comments: Signatures: Representatives from the pearntnod Mcility and the conh`acted rostitrg cautpany Quist mrnvide signatures below certifying that the information provided on this form and any attached information is accurate and complete. YP / ��✓v ' r ,r r�� �fJ l f o f pit a , ottnitted Facility Ropresontative [)ate T4k0ng Company Representative [)etc Name: Nelson Breedwr I 'Nmne: .luene Franklin,P.b. Title; Eastern Region Engineer title: Branch Manger Cornpanp: Anson Waste Manageineu Facility j Company': Riley,Park,Iiayden&Associates, Inc. APPENDIX B AWM Tier 2 Test NCDENR Approval Letter �..`L NCDENR North Carolina Department of Environment and Natural Resources Division of Air Quality Beverly Eaves Purdue Sheila C. Holman Dee Freeman Governor Director Secretary November 29,2011 Nelson Breeden - Eastern Region Engineer Anson Waste Management Facility 375 Dozer Drive Polkton,NC 28135 Subject: Protocol for Non-Methane Organic Compounds(NMOC)Retesting on Candlestick Flare CD-1 Anson Waste Management Facility(AWM)in Polkton,Anson County,North Carolina Air Permit No. 09835R00,Facility ID 04/04/00052 Proposed Test Date:December 15,2011 Tracking No.2011-224ST Dear Mr.Breeden: The protocol submittal form(PSF)prepared by Riley,Park,Hayden and Associates,Inc.has been reviewed for non- methane organic compounds(NMOC)emissions testing and deemed acceptable. The candlestick flare is subject to 40 CFR 60 Subpart W W W Standards of Performance for Municipal Solid Waste Landfills. This is a New Source Performance Standard(NSPS)Tier 2 retest in accordance with 40 CFR 60.754(a)and(b). According to 60.754(a)(1)(ii)If the calculated NMOC emission rate is equal to or greater than 50 megagrams per year(Mg/yr), then the landfill owner shall either comply with 60.752(b)(2), or determine a site-specific NMOC concentration and recalculate the NMOC emission rate using the procedures provided in paragraph(a)(3) (Tier 2) of this section. A Tier 2 test was conducted on September 22,2009. The report shows that AWM will exceed the NMOC emission rate of 50 megagrams per year(Mg/yr)in 2011 by 1.3 Mg/yr. Without conducting an additional Tier 2 retest,AWM would be required to submit a NSPS Gas Collection and Control System(GCCS)design plan on or before September 22,2012. The emission source is a candlestick flare ID No.CD-1. The maximum permitted process rate is 2,500 standard cubic feet per minute(scfm). The maximum normal operation process rate is 373 scfm. The target process rate is 250 to 2,500 scfm. The source,pollutants,and methods are tabulated below: Candlestick Flare CD-1 Carbon Dioxide,Methane, M3C Nitrogen and Oxygen NMOC M25C Technical Services Section 1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One 2728 Capital Blvd.,Raleigh,NC 27604 NorthCarolina Phone: 919-715-0531/FAX 919-733-1812/Internet: www.ncair.org Naturally An Equal Opportunity/Affirmative Action Employer-50%Recycled/10%Post Consumer Paper Nelson Breeden November 29,2011 Page 2 of 2 The proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not exempt the tester in any way,from the minimum requirements of the applicable methods. Since no deviations from the applicable testing methodology were addressed in the test protocol,the testing should be conducted in strict accordance with the requirements of EPA Methods 3C and 25C. Any modifications to the applicable test methods remain subject to approval by the Division of Air Quality. Please insure all relevant process/operating data is included and summarized in the test report. If you have any questions, please feel free to contact me at David B Hu Ig res.@ucdenr.7ov or(919)707-8411. Sincerely, David B.Hughes Environmental Engineer Cc: Juene Franklin,Riley,Park,Hayden,and Associates,Inc. Mitch Revels—Fayetteville Regional Office Central Files—Anson County IBEAM Documents—0400052(12/15/11) Riley, Park, Hayden & associates, Inc. 2600 South Loop, Suite 320 Telephone: (713) 333-0444 Houston, Texas 77054 Fax: (713) 333-0445 October 27, 2011 E E I V F Mr. Steven Vozzo Regional Supervisor OCT 31 2011 North Carolina Department of Environment&Natural Resources Fayetteville Regional Office DENh 225 Green Street, Suite 714 EAYErrEVILLE REGIONAL 0rf-i,. Fayetteville,NC 28301 Subject: Anson Waste Management Facility Additional Tier 2 Retest Protocol Chambers Development of North Carolina, Inc. Additional Tier 2 retest request(40 CFR 60.754(a) & (b) Title V Permit No. 09835R00 Facility ID No. 0400052 Dear Mr. Vozzo: On behalf of Anson Waste Management Facility (AWM); Riley, Park, Hayden &Associates, Inc. (RPH) submits a request to conduct an additional NSPS Tier 2 retest in accordance with 40 CFR 60.754 (a) & (b). Justification for the retest along with field sampling protocol, summary of analytical testing methods, and North Carolina Department of Environment & Natural Resources (NCDENR) protocol form has been included in this request for your review and approval. INTRODUCTION Chambers Development of North Carolina, Inc. owns and operates AWM. AWM operates an active solid waste management facility that is subject to the requirements of New Source Performance Standards (NSPS) because the AMW design capacity is > 2.5 million megagrams and > 2.5 million cubic meters. The facility operates a Gas Collection & Control System (GCCS) under existing Title V Permit No. 09835R00 that was voluntary installed to control odors and prevent migration landfill gas (LFG). SCS Engineers conducted a Tier 2 test on September 22, 2009. The report shows that AWM will exceed the NMOC emission rate of 50 Mg/yr in 2011 by 1.3 Mg/yr. Without conducting an additional Tier 2 retest, AWM would be required to submit an NSPS GCCS design plan on or before September 22, 2012. JUSTIFICATION FOR ADDITIONAL TIER 2 RETEST A determination letter written by the Environmental Protection Agency (EPA) Region 5 on December 13, 2002 has set precedence for a facility to conduct an Additional Tier 2 Retest provided that the facility follows time-lines set forth in 40 CFR 60.752(b)(2)(i) and 40 CFR 6.0.752(b)(2)(ii). A copy of this determination letter is displayed in Appendix A of this document. The letter indicates that the facility is allowed to conduct an Additional Tier 2 Retest as long as long as compliance deadlines associated with the NSPS GCCS Design Plan or GCCS operating/record-keeping/reporting requirements 1 Anson Waste Management Facility Additional Tier 2 Retest Protocol North Carolina Dept. of Environment & Natural Resources Existing Title V Permit No.09835R00 October 27, 2011 have not been missed. Based on the current Tier 2 Test results, the NSPS GCCS Design plan is not due until September 22, 2012, Moreover, the GCCS is not subject to the operational/record- keeping/reporting requirements of NSPS until March 22, 2014. In addition, EPA's Municipal Solid Waste Landfill New Source Performance Standard (NSPS) and Emission Guidelines (EG) Questions and Answers — Revised November 1998 (EPA Q&A document) also states that a facility with a GCCS already in place is allowed to recalculate NMOC concentration in accordance with the requirements of 40 CFR 60.754(b), For your review and consideration, an excerpt of EPA Q&A document is included in Attachment B of this document. PROPOSED GCCS SAMPLING PROCEDURES As specified in 40 CFR 60.754(b) and the EPA Q&A document, the LFG samples will be collected in accordance with the following procedures: • Prior to sampling at least 2 probe volumes will be evacuated from the system at a flow rate of 500 ml/min or less. The samples will be tested using a GA 90 portable LEG Monitoring unit to make certain that the samples acquired contained less than 20% nitrogen or, alternatively, less than 5%oxygen. • A total of four (4) passivated, helium pre-filled, summa canisters will be. used to obtain the samples. Three (3) of the canisters will be used to collect samples from the header inlet upstream of the KOP; while, a fourth will be used as a spare. • Upon completion of field sampling the summa canisters will be sent via overnight mail to a NELAP-approved analytical laboratory for analysis in accordance with EPA Method 25C/3C protocols. • We will record the LEG flow rate at the time of sampling during the Additional Tier 2 Retest. We will record the LEG flow as standard cubic feet per minute (scfm) and later convert the flow rate into cubic meters per minute (cmm). • Finally we will perform a surface scan on the areas influenced by the existing GCCS. NMOC Emission Rate Calculation and Report Preparation As previously mentioned, the NMOC emission rate will be calculated using the formula specified in 40 CFR 60.754(b). In the event that revised NMOC emission rate falls below the 50 Mg/yr threshold, a revised Tier 2 test will be submitted to the NCDENR. In the event that the NMOC emissions are calculated to fall below 50 Mg/yr for five (5) consecutive years, the report will serve as the 5-year report. Should the results show that the facility will not satisfy the 5-year report criteria, AWM will use the additional Tier 2 report to serve as the first of a series of annual NMOC emission rate reports. The annual NMOC emission rate reports will continue to be submitted to NCDENR until the next Tier 2 test is required or until the revised NMOC rate equals or exceeds 50 Mg/yr. 2 Anson Waste Management Facility Additional Tier 2 Retest Protocol North Carolina Dept. of Environment & Natural Resources Existing Title.V Permit No.09835R00 October 27, 2011 Also, as required by NCDENR, we have included a copy of the Division of Air Quality's Protocol Submittal Form (Appendix C). Please note that we have answered no to Sections 2.3, 2.4, and 2.8 of the Protocol submittal form because they do not apply. We trust that this request along with field sampling procedures and analytical testing procedures meet NCDENR requirements. Please don't hesitate to call Nelson Breeden at (865) 200-7650 or Juene Franklin at (832) 244-1980 if you have any questions, or require additional information to process the attached Tier 2 retest request. Sincerely, Riley, Park,Hayden & Associates, Inc. Riley, Park, Hayden & Associates,Inc. Scott Tarkington Juene Franklin, P.E. Project Manager Branch Manager Enclosures: Appendix A EPA Region 5 December 13, 2002 determination letter Appendix B November 1998 EPA NSPS Q&A Document (Excerpt) Appendix C NCDENR air quality protocol Appendix D Existing GCCS site plan Appendix E System process flow diagram Appendix F Typical flare schematic sampling port location cc: w/attachments Kurt Shaner- Waste Connections, Inc. Eastern Regional Engineering Manager Nelson Breeden -Waste Connections, Inc. Eastern Region Engineer 3 PROTOCOL SUBMITTAL FORM (Rev. 2010a) N4DER DIVISION OF AIR QUALITY PAGE 1 of 2 Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility, the testing consultants, and the DAQ as well as to identify and resolve any specific testing concerns prim to testing. Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAO Regional Supervisor at least 45 days prior to testi»2. Complete one form.for each sampling location. if this form does not supply sufficient space to completely answer all questions or if additional relevant information is necessary, attach additional documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate Regional Supervisor. This form and its Guidance Document are available from the DAQ website(http://daq.state.ne.us/enf/sourectest� Specify Appropriate Regional Office: (check one) ❑Asheville ® Fayetteville ❑Mooresville ❑Raleigh ❑Washington ❑Wilmington ❑ Winston-Salem Facility Name: Anson Waste Management Facility Testing Company: Riley,Park,Hayden,and Associates,Inc. Facility ID No: Facility Contact Person/mailing address&email: Testing Company Contact Person/mailing address& email: Anson County Landfill Riley, Park,Hayden, and Associates,Inc. 375 Dozer Drive 2600 South Loop West, Suite 320 ?olkton,NC 28135 Houston,Texas 77054 Anson County Juene Franklin ryler Fitzgerald Branch Manager E.Inail Address: TylerF@WasteConnections.com Email Address:jfranklin@rphengineering.com 3hone: 704-694-6900 Fax: 704-694-2537 Phone: (713)333-0444 Fax: (713)333-0445 vlobile No.: 704-965-7562 Mobile No.: (832)244-1980 air Permit Number&Revision: 09835R00 -Application No. Permitted Source Name and ID No.: Candlestick Flare, CD-1 )400052.10A 'ermitted Maximum Process Rate: Maximum Normal Operation Process Rate: Target Process Rate for Testing: ',500 scfm 373 scfm 250 -2,500 scfm 1)What is the s en cific propose for the proposed testing? (permit condition,NSPS,NESHAP, etc, see guidance doc): Conduct Tier 2 retest to determine NMOC generation rate(Mg/yr). Is this an initial performance test? ❑ Yes or ®No .2)List all state and federal regulations that apply to the proposed testing(see guidance doc): 40 CFR 60.754(a) &(b) .3) Will the test results be used for other regulatory purposes(e.g., emission inventories,permit application, etc.)beyond that stated above? ❑ Yes or ®No If yes, explain. 4)How will production/process&control device data be documented during testing(list specific control equipment,process parameters, instrumentation that will be used,frequency of data collection, collected by computer/manually,etc.)?TEST WILL NOT BE ACCEPTED WITHOUT APPROPRIATE PRODUCTION/PROCESS &CONTROL DEVICE OPERATION DATA. All field testing process data will be documented on field logs and submitted with an Additional Tier 2 Retest report after analytical data is received from Air Technology Laboratory. 5)Provide a brief description of the source(including control equipment)and attach source or process flow diagram from source through stack exit: Anson is a non-hazardous solid waste facility. Biodegradation of waste mass produces landfill gas(LFG) as a by-product. Blowers induce a vacuum on gas extraction wells that extracts LEG from the waste mass through a HDPE piping network. The collected LEG is then burned at the flare. A process flow diagram is included in Appendix E of this document. 6)Provide a brief description of the sampling location, attach schematic of sampling location,and indicate whether concurrent testing will be conducted at other sampling locations(Approval of protocol without this data will not exempt you from Method I criteria): Three gas samples will be collected from the header pipe before the gas moving equipement(blowers) or condensate removal equipment (Knock-out Pot). A site plan is included in Appendix D and a typical flare skid schematic of sample port location is included in Appendix F of this document. a .�".• PROTOCOL L SUBMITTAL FORM (Rev. 20kOa) MCDENR fl)MSION® FAGE 2 DF 2 2.1)Provide the following information for each test parameter. Target Proposed Number of Test Run #of Sampling Comments Pollutant Test Method Test Runs Duration Points n/a- n/a Tier 2 Report show NMOC calculations EPA Methods Approx 1 14MOC 25C/3C Collect 3 hr/sampl 1 completed as outlined in 40 CFR Samples e 60.754(b) 2.2) Will all testing be conducted in strict accordance with the applicable test methods? If answer is no,attach ®Yes ❑No complete documentation of all modifications and/or deviations to the applicable test methods. 2.3) Does the proposed sampling location meet the minimum EPA Method I criteria for acceptable measurement sites? ❑Yes ®No Attach supporting documentation. 2.4) Has cyclonic flow been documented at this source(EPA Method 1 Section 11.4)? ❑Yes ®No ABSENCE OF CYCLONIC FLOW MUST BE VERIFIED DURING CURRENT TESTING. 2.5) Will the oxygen concentration be determined by®EPA Method 3 via Orsat or❑strict EPA Method 3A ®Yes ❑No (specify)If answer is no,see Question 2.2 above.(Fyrites are NOT allowed per 15A NCAC 2D.2606) 2.6) Do any of the proposed test methods require analysis of EPA audit samples? If yes,notify Regional Office ❑Yes ®No a minimum of 45 days prior to testing to allow for audit sample preparation and shipment. 2.7) Has all testing equipment been calibrated within the past year^ if answer is no,explain. ®Yes ❑No 2.8a)Have all calibration gases been certified by EPA Protocol 1 procedures?(Answer only as applicable) ❑Yes ®No 2.8b)Is a dilution system(via EPA Method 205)proposed?(Answer only as applicable) ❑Yes ®No 2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods. 2.9) What is proposed test schedule?DAO Regional Supervisor must be notified a minimum of 15 days prior to the actua)test date s) THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION December2011 Additional Comments: Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying that the information provided on this form and any attached utformation is accurate and complete. f jV' L. �`'-�A8'nD/ ' "�°"t-4 /��,✓t, � ;rr f.' f ley^n Permitted Facility Representative Date lysting Company Representative Date Name: Nelson Breeden Name: Iuene Franklin,P.E. Title: Eastern Region Engineer Title: BraitchMaoger Company: Anson Waste Management Facility Company: Riley,Park,Hayden&Associates,Inc.