AQ_F_1100542_20140714_ST_RvwMemo

Western North
Carolina Regional Air
QUality Agency
Memo
To: File,`facility#11-542, Buncombe County Landfill II
From: `Ashley Featherstone/Betsy Brown
CC: David Brigman
Date: March 21,2014 and July 14,2014
Re: Source Testing at Buncombe County Landfill II
In November of 2011, Buncombe County Solid Waste(BCSW)completed construction of a 1.4 MW
landfill gas-to-energy project at the site. This project utilizes a landfill gas collection system and one
GE/Jenbacher electrical generator set, Model JGS 420,fired by landfill gas,with a maximum rated heat
input capacity of 17 MMBtu/hr(engine output capacity is 1,966 HP,generator output capacity is 1,466
kW).
Air Quality Permit No.'11-542-10 A(Part I,Section 2, Condition 2.1(13)(1))includes requirements
associated with 40 CFR Part 60 Subpart JJJJ—"Standards of Performance for Stationary Spark Ignition
Internal Combustion Engines." The NSPS requires performance testing if the generator is not certified by
the manufacturer to meet the NSPS BCSW has notified the agency that the generator was not certified
by the manufacturer to meet those standards.As such, BCSW was required to conduct an initial
performance test within 60 days after achieving the maximum production rate at which the affected
facility will be operated, but not later than 180 days after initial startup of the facility:On January 13,2012,
BCSW informed the agency that the maximum production rate for the generator was reached on January
3,2012. Testing occurred on February 21,2012 and showed compliance with the emissions limitations.
The NSPS requires subsequent performance testing every 8,760 hours or 3 years,whichever comes
first,thereafter to demonstrate compliance. Subsequent testing occurred on February 5,2013, and the
results indicated compliance with all permitted limits.
On February 4, 2014, Joe Wiseman of Petra Engineering submitted a source test notification form for the
subsequent testing that was scheduled to occur on March 20,2014 at BCSW. In the notification letter,
Mr.Wiseman indicated that the engine did not operate as frequently as it had the previous year and as
such,the requirement to retest every 8,760 hours was met. David Brigman and Betsy Brown arrived at
BCSW to observe the testing at 9:35 am on March 2e. Kirk Alexander and Sean Huber with GEL
Engineering and Joe Wiseman of Petra Engineering were onsite. Aaron McKinzie of BCSW was also
onsite during the testing. The first one hour test run was started @ 10:12 am.
At 10:15 am,the electrical output of the generator was 1,350 kW. The landfill gas flow rate to the engine
was 415 scfm. GCS inlet vacuum was 19.1 inches water column. The temperature of the exhaust gas
was 573 degrees F. Aaron McKinzie of BCSW was monitoring the exhaust gas temperature for the 20
engine cylinders. If the temperature exceeds 590 degrees F,the engine is programmed to power off.
Mr. Brigman and Ms. Brown left the site at 10:25 am.
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The results were received.on May 19,2014,which met the requirement in Subpart JJJJ which states that
the report must be submitted no later than 60 days after the completion of the performance test(40 CFR
60.4245(d)) It appears that all required procedures and methods were followed.
With a rating of 1,466 kW, the engine is required to be operated in a range from 1,319 to 1,612 kW
during the testing. The source test report included kW output data that was recorded every 15 minutes
during the testing, which started at 10:13 am and concluded around 1:43 pm. The minimum power
output was 1,350 kW and the maximum power output was 1,354 kW,which is within the required range.
The results from the report show compliance with the standards and are listed in the table below.
Emission Limit Average Test
Pollutant EPA Method Concentration(ppmvd
(ppmvd @ 15%DZ) @ 16%02)
Oxides of nitrogen 7E 150 59.5
Carbon monoxide 10 610 244
Volatile Organic 25A 80 9.0
Compounds
Conclusions,Comments,and Recommendations.
A letter will be sent to BC_SW stating that the WNCRAQA accepts the results of the testing.
Signature:— ,� n� Date: I��!i g
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