AQ_F_1100542_20160902_ST_ProtRvw

PAT MCCRORY
N,
Governor
Air Quality DONALD R. VAN DER VAART
ENVIRONMENTAL QUALITY
.Secretary
September 2,2016
Ms.Kristy Smith,Bioreactor Project Manager
Buncombe County Landfill II
81 Panther Branch Road
Alexander,NC 28701
Subject: Protocol for Tier 2 Testing for Non-Methane Organic Compounds Emissions from the
Buncombe County Landfill 11,Alexander,Buncombe County,North Carolina
Facility ID 11/00542,Air Permit No. 10398T00,
By Environmental Infrastructure Consulting PLLC (EIC)
Proposed Test Date: September 8,2016
DAQ Tracking No.2016-181st
Dear Ms. Smith:
The North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)
regarding Tier 2 emissions testing for non-methane organic compounds(NMOC) emissions from the
landfill as revised by email dated 8-11-2016. The proposed 5-year update testing protocol submitted
September 2,2016 is acceptable as discussed below.
The source is a municipal solid waste landfill ID ES-C 1 with a leachate recirculation system, consisting of
a 121-acre disposal area. A landfill gas collection and control system CD-GC CS1,consisting of 25
vertical extraction wells, lateral piping, a 300 to 3000 standard cubic feet per minute(scfin)two-stage
landfill gas(LFG)-fired flare to control emissions, and one landfill gas-fired engine/generator set
(1966hp/1466kW output capacity) are currently installed.
40 CFR Part 60, Subpart WWW Standards of Performance for Municipal Solid Waste Landfills applies.
This testing is to determine whether the site-wide NMOC emissions remain below the 60 Subpart WWW
50 megagrams per year(Mg/yr)threshold requiring installation and operation of a landfill gas collection
and control system. For Buncombe County Landfill Il, a landfill gas collection system was installed to
support the LFG to energy project(LFGTE). 60 Subpart WWW allows the landfill to estimate annual
NMOC emissions using waste-in-place data and/or to conduct emissions testing to develop site-specific
emission rates.
Buncombe County proposes Tier 2 NMOC emissions testing of the landfill"to determine the five-year
update for site-specific non-methane organic carbon(NMOC) concentration at LandfilllI". Testing will
be conducted using the gas collection and control system. Twenty-five(25)vertical wells are in cells 1
through 5 to collect LFG. Four horizontal gas collectors collect LFG in cell 6. The collected LFG is
ducted to a common header where it mixes and flows to the moisture knock-out ports then to an induced
draft fan system(blower). The flare control device and the LFGTE engine/generator are located
downstream of the ID fan. The flare will not operate during testing.
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641

Ms.Kristy Smith
September 2, 2016
Page 2 DAQ Tracking No. 2016-181 st
Buncombe/EIC has proposed the test methods in the following table.
Target Pollutant Proposed Test Method
Methane, Oxygen, US EPA Method 3C Determination of Carbon Dioxide, Methane,
Carbon Dioxide, Nitrogen, and Oxygen from Stationary Sources
Nitrogen
Non-Methane Organic US EPA Method 25C Determination of Nonmethane Organic
Compound(NMOC)— Compounds (NMOC) in Landfill Gases
as hexane
The proposed test methods are acceptable. EPA Methods 3C and 25C shall be performed as allowed in
40 CFR 60 Subpart WWW to collect LFG samples in a minimum of 3 Summa canisters. EIC proposes
collecting 5 canisters of LFG and an additional canister as a blank. This is acceptable.
40 CFR 60 Subpart WWW requires a minimum of 2 probes(or wells in this case)per hectare of landfill
surface area that has retained waste for at least 2 years to be sampled. There are 25 vertical wells in
landfill cells I through 5 for a surface area of 12.95 hectares. Thus the gas collection system has
approximately 2 wells per hectare. Cell 6 has 5 horizontal collection headers connected to the perimeter
LFG header. All testing will be performed at the common header for Cells 1 through 6. This is
acceptable.
The Method 25C and 3C test data and sampling analysis results will be used to determine the site specific
NMOC value for the EPA Landfill Gas Emission Model(LandGEM) 5-year annual estimate of landfill
emissions. Please include the complete lab report and the LandGEM model in the final test report. Please
include the supporting full size drawings of the landfill collection system with the final test report.
In conclusion, the test protocol is approved. Approval of the protocol does not exempt the tester from the
minimum requirements of the test methods. Any deviations from the methods or 60 Subpart WWW
requirements remain subject to approval by DAQ. If you have any questions regarding the results of this
review,please contact me at(919) 707-8412 or at [e-mail].
Sincerely,
James E. Hammond,Environmental Engineer
NC Division of Air Quality,NCDEQ
cc: Joseph F. Wiseman,Jr, EIC
Brendan Davey,Asheville Regional Office
Central Files, Buncombe County
IBEAM Documents— 1100542