Loading...
HomeMy WebLinkAboutAQ_F_1100542_20170712_CMPL_InspRpt (4) f t NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Buncombe County Landfill II NC Facility ID 1100542 Inspection Report County/FIPS:Buncombe/021 Date: 07/12/2017 Facility Data Permit Data Buncombe County Landfill II Permit 10398/TO 81 Panther Branch Road Issued 9/1/2016 Alexander,NC 28701 Expires 11/30/2019 Lat: 35d 43.7288m Long: 82d 37.9998m 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 Kristy Smith Jon Creighton Kristy Smith MACT Part 63: Subpart ZZZZ Bioreactor Manager Assistant County Bioreactor Manager NSPS: Subpart Cf, Subpart JJJJ, Subpart WWW (828)250-5462 Manager (828)250-5462 (828)777-3853 Compliance Data Al Comments: Inspection Date 07/12/2017 Inspector's Name Mike Parkin Inspector's Signature: ` ` � % f / .;, Operating Status Operating Compliance Code Compliance-inspection / Action Code FCE Date of Signature: f 1'`> On-Site Inspection Result Compliance / 17 Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2015 1.69 0.7700 12.32 6.57 32.10 1.69 1594.23 2014 1.54 0.9800 9.62 6.01 31.58 1.54 1493.50 2013 1.54 0.9500 10.22 5.94 26.78 1.54 1446.00 *Highest HAP Emitted(in pounds) Five Year Violation History: Date Letter Tyne Rule Violated Violation Resolution Date 07/29/2015 NOV/NRE Permit Permit Condition 01/19/2016 Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 04/04/2017 Compliance Method 10,Method 25A,Method 7E ES-CI 10/07/2016 Pending 05/19/2016 Compliance Method 0010,Method 25A,Method 7E ES-GI Directions: Take 1-26 N from Asheville to exit 21. Turn left onto New Stock Rd and drive 0.8 miles. Turn left on Aiken Road and drive 0.3 miles. Turn right on Goldview and go about 1.6 miles to the river. Turn right on Riverside Drive/NC 251 Buncombe County Landfill II Inspection Report—7/12/17 Page 2 = and drive approximately 4.5 miles to Panther Branch Road. Turn right onto Panther Branch Road and the facility will be located on the right at 81 Panther Branch Road. Safety Equipment:Earplugs and safety shoes. Note:This facility was previously under the jurisdiction of the local air quality program,WNCRAQA.As of July 18,2014, jurisdiction was transferred to NCDAQ.The reason for the transfer was due to an employment sharing arrangement with the Buncombe County Solid Waste Department. Facility Description: The Buncombe County Solid Waste Department(BCSW)operates the Buncombe County Landfill II,a municipal solid waste(MSW) landfill. In addition to operating the RCRA(40 CFR 258) Subtitle D landfill,the Buncombe County Solid Waste Management Facility operates a construction and demolition (C&D) landfill, wood waste mulching facility, convenience center for residential solid waste drop-off, a household hazardous waste (HHW) facility, and a white goods and tires holding facility at this location. Construction of the landfill began in 1993 and waste acceptance began in October 1997. The facility has a design capacity of approximately 3.17 million megagrams (Mg) and 3.16 million cubic meters (m3) of refuse and is estimated to provide 35 years of operation. As the design capacity is in excess of 2.5 million Mg and 2.5 million m3 of refuse, the landfill is regulated as a Title V source per applicable requirement in 40 CFR Part 60, Subpart WWW—"Standards of Performance for Municipal Solid Waste Landfills," Section 60.752(c). The landfill operates 7:30 AM - 4:30 PM M-F and a '/2 day on Saturday. The engine operates around the clock unless there are problems. The tub grinder has previously been reported to operate 1 day per month for day. I, Mike Parkin met with Aaron McKenzie,Power Plant Operator to inspect the facility. Kristy Smith, Bioreactor Manager, had the day off and was not available. The purpose of this site visit was to conduct a routine air quality inspection of the Buncombe County landfill, a municipal solid waste (MSW) landfill. A summary of observations while at the facility is as follows: 1. The following permitted air emission sources and control devices were observed as follows: INN �w 91 ES-C1 Municipal solid waste landfill with a leachate CD-GCCS1 ** One landfill gas collection NSPS Subpart WWW recirculation system,consisting of a 121 acre and control system including: disposal area CD-1** One two-stage landfill gas- fired candle-stick type flare (300 scfm minimum flow rate and 3000 scfin maximum flow rate) The landfill was in operation at the time of inspection,with loading occurring at Cell 6. Area I includes Cells 1 through 6. Cells 1 through 5 have been closed for years. Waste addition to Cell 6 began in October of 2006. It was reported during the previous inspection that Cell 6 is expected to be open and active for 4-6 more years. Leachate is recycled 2-3 days per week for 3-4 hours typically during April through December. The 3,000 acfin flare was operating at the time of inspection in part due to the generator being down for maintenance. The 300 acfin flare was not operating during the inspection.The flares cannot operate at the same time. The gas duct for the smaller flare is attached to the duct of the larger flare and both flare burners are in the same wind enclosure. The original blower skid painted gray serves the main flare and was originally capable of delivering 3,000 acfin of landfill gas(LFG). Mr.McKenzie stated that the capacity is somewhat less than that at this time due to some changes in the system. The other blower skid painted beige and located closer to the generator can pump 500 acfm and supplies the generator engine which he states uses about 450 acfin. Any excess gas can be sent to the smaller(300 acfin)flare which is only supplied by the lower capacity blower skid. I believe the 3,000 acfm skid is capable of supplying LFG to both the engine and large flare simultaneously. Mr.McKenzie stated that recently they had been flaring LFG Buncombe County Landfill II Inspection Report—7/12/17 Page 3 with the large flare and running the generator at the same time recently to determine how much LFG they could get from the system. The following data on the flares was recorded during the inspection: VE 0% LFG flow to flare 1 282 acfm LFG flow to flare 2 0 LFG flow to generator 0(down for 10,000 hour maintenance) flare 1 LFG total 1477255 ?CF(not clear on the units;panel difficult to read due to bright sunlight;may have misses decimal point as well) flare 2 LFG total not observed total runtime—flare 1 not observed total runtime—flare 2 combustion temp—flare 1 1,540°F combustion temp—flare 2 not operating vacuum 11.35"of water From a previous WNCRAQA inspection: The flare was not operating at the time of the inspection. The flare station has a flow capacity of 3,000 scfm. During the inspection in 2009, Ms.Smith reported that they had not been operating the flare because it was designed to operate with a minimum airflow rate of 300 scfm. The typical flow rate at this time is only around 250 scfm. The system is fired with propane and when it is operated at this low flow rate, a sensor triggers the propane to keep the flare lit. As a result, the flare burns propane continuously and is not economical to operate. The manufacturer of the flare has advised that it not be operated on a regular basis under these conditions. The flare operated for only 208 hours in 2009. It did not operate in 2010. The flare system began operating again in November of 2011 when the generator began operating. As noted below in the section that addresses the electrical generator set, a smaller flare has been added to flare excess gas from the system. The addition of the smaller flare does not increase the maximum capacity of the flare system. Please see that section for additional details. The heat sensing device and landfill gas flow rate measuring device that were initially installed and operated on the original flare system have been replaced with a new monitoring system that meets the EPA Greenhouse Gas(GHG) Monitoring Rule requirements. Methane and several other parameters are monitored on a continuous basis. EPA has not delegated enforcement authority of the monitoring rule to the state and local programs. BCSW has indicated that they are reporting their GHG information to EPA in accordance with those requirements. ES-GI One landfill gas-fired engine/generator set None None NSPS Subpart JJJJ (engine= 1966 hp, 17 mmBtu/hr heat input MACT Subpart ZZZZ capacity and generator=1466 kW output capacity) The engine generator or genset produces electricity to be sold to the electric grid. The generator engine was recently replaced with an identical rebuilt engine. The new engine was reported to begin operation on April 1, 2016. In accordance with NSPS Subpart JJJJ a compliance test is required with 60 days of startup (by May 31, 2016 in this case)of a rebuilt/remanufactured engine. The test was conducted on May 19,2016 and results indicated compliance with NSPS limits see detailed test results later in this report. The most recent test was conducted on April 4, 2017 and indicated compliance;test results are later in this report. Mr. McKenzie stated that the engine was down for 10,000 hour maintenance. A company by the name of Nixon is contracted to do the maintenance and they were onsite at the time of inspection. It appeared the person performing Buncombe County Landfill II Inspection Report—7/12/17 Page 4 the maintenance was adjusting the valves at the time of inspection. Mr. McKenzie stated as part of the 10,000 maintenance the following items are addressed(this is not a complete list): • bore scope to check condition of cylinders ® spark plugs changed • oil changed • thermocouple on intake replaced • replacing?vibration dampeners • checking air intake louvers Mr. McKenzie stated they will clean siloxane build up on heads after every 3,500 hours of operation. He stated a top in rebuild would occur after about 20,000 hours of operation. The engine data observed during inspection and testing is noted below: SM AMIN VE n/a-down 0% Power output n/a 1351 kW (kW being produced) set point: 1350 kW Total volume n/a 767.77 mmSCF (since began operation) (includes previous engine) Fuel(LFG)flow n/a 400 scfin (generator gas flow) Fuel pressure n/a 4.9 psi at blower;49.3%of range LFG data(analyzer at n/a CH4=54.7% blower) 02=0.59% total engine operating 10,578 1,056 hours Engine speed n/a 1800 rpm(has to be this RPM to generate electricity at 60 Hz %methane and oxygen n/a 53.2/53.5%and 0.0% Combustion temp flare n/a NA Avg.exhaust temp. n/a 574°C #of starts since installation 152 Blower skid data inlet vacuum=n/a inlet vacuum=6.9" LFG temp.=n/a LFG temp.=69°F LFG pressure=n/a LFG pressure=4.9 psi(?) LFG flow=n/a LFG flow=398 scfm max capcity=500 scfin per max capcity=500 scfin per late plate A gas conditioning system,including a knock out box,2 filters,and a cooler,has been installed to remove moisture prior to gas combustion in the engine.The engine also has a filter. From the 2013 WNCRAQA inspection:Mr. McKinzie indicated that the flow restrictor on the small flare was being replaced at the time of the inspection. GI is scheduled for maintenance on October 14'. They plan to flare the landfill gas with the smaller flare while the engine is not operational. Mr. McKinzie performs many of the maintenance activities himself. BCSW also contracts with a company called Nixon to perform scheduled maintenance and troubleshoot any issues with the engine. The engine began knocking this week and Nixon has determined that this is due to a buildup of siloxanes from the gas which seems to be happening at a faster rate than Buncombe County Landfill II Inspection Report-7/12/17 Page 5 normal. The maintenance work schedule was adjusted in response and they are operating at a lower rate until the work can be performed. A Supervisory Control and Data Acquisition System (SCADA)system(which can be seen from Mr. McKinzie's office) is utilized to track operations by monitoring:total gas flow rate(scfm), total gas volume(since the engine began operating), generator gas flow, generator gas volume,flare operating hours, total engine operating hours, % methane and oxygen, and temperature of combustion gases in the engine and the flares. Combustion temperature, as measured in the 20 engine cylinders, must be at least 500 degrees F for carbon credits. The system collects data every 15 minutes and a daily electronic summary is generated the following day. At 10:16 am, the system showed that the landfill gas temperature was 89 degrees F Flow rate to the engine was 344 scfm. Mr. McKinzie stated that the typical flow rate to the engine is between 410 and 430 scfm. The electrical output of the engine was 1,073 kW at 10:35 am. Typical output is higher, around 1,400 kW They are operating at around 1,200 kW this week since it has been determined that maintenance is needed on the engine. Operations will remain at this level or lower until the maintenance is completed on October 141. Methane and oxygen sensors were not operational. Mr. McKinzie reported that the replacement sensors had been ordered and that in the interim, they were taking methane and oxygen readings with a portable landfill gas analyzer once a day. On September 24'" oxygen was 0.4%and methane was 59.1%of the gas stream. Since beginning operations in November of 2011, the engine has logged 13,227 hours of operating time. At 10:35 am, the system in the control room next to the engine showed that the electrical output of the generator was 1,073 kW. The temperature sensors for the 20 cylinders showed a temperature for each cylinder and a data summary. The minimum temperature was 560 degrees F and the maximum temperature was 584 degrees F. At 10:38 am, the engine flow rate on the flare skid data system was 343 scfm. Total flow rate to the flare was 0 scfm. 2. Notes on non-permitted air emission sources are as follows: LOA MUMS IES-TGI One Diesel fuel-fired Morbark tub grinder,Model 1200(nonroad engine,650 hp capacity) The grinder was not observed. Mr.McKinzie stated that grinder is onsite but was not sure it was operating at the time of inspection.Per the 2014 inspection: The grinder serial number was 869106 and the hour meter indicated 216 hours. The engine remains on site 99%of the time but is occasionally moved off-site to the old landfall, on the site, or to the maintenance area. It mounted on a skid with wheels. Per a previous"CRAQA inspection: The tub grinder was onsite but was not operating during the inspection. The tub grinder is used to make mulch that BCSW can sell or mix with soil to make an alternative daily cover material for the landfill. The majority of the material that is processed by the tub grinder is brush and pallets. Painted and pressure treated wood must be removed from the material pile that will be processed by the grinder as required by solid waste rules, which do not allow those materials to be incorporated in the daily cover material for the landfill. Painted wood and other non-compliant materials are separated from the other materials and placed in a dumpster to prevent them from being processed by the grinder, as required by the Division of Solid Waste. Per the 12/4/2015 permit review: It was previously determined that the Diesel fuel-fired engine met the requirements of a "nonroad engine"in 40 CFR 1068.30 which makes the engine exempt from being permitted as a stationary source. The tub grinder is expected to emit less than five tons per year of any criteria pollutant(not including the emissions from the nonroad engine) and is therefore being placed in the cover letter as an insi ni acant activity. IES-01 One storage tank with two compartments(one compartment that stores 10,000 gallons of off-road Diesel fuel,and one compartment that stores 2,000 gallons of gasoline)-not observed. IES-02 One Diesel fuel storage tank(6,000 gallon capacity) not observed. IES-03 On leachate pond(30,000 square feet of surface area, 1,000,000 gallon capacity)-not observed. Buncombe County Landfill II Inspection Report—7/12/17 Page 6 3. Compliance with specific permit conditions and limitations: GAS SYSTEM WITH FLARE 2.I.A.1 NSPS Subpart WWW—Standards of Performance for Municipal Solid Waste Landfills- Per the previous WNCRAPCA inspection: Air Quality Permit No. 11-542-IOA (Part I, Section 2, Condition 2.1(A)(1)) requires the landfill to comply with the requirements of 40 CFR Part 60, Subpart WWW. This Subpart stipulates that the landfall shall install and operate a GCCS after the non-methane organic compound (NMOC) emission rate equals or exceeds 50 Mg per year. Tier 2 testing is required by the Subpart at least every 5 years to determine when a GCCS is required. Tier 2 testing was last conducted in October of 2011. Based on the average NMOC concentration obtained from the Tier 2 testing, the revised NMOC emission rate was calculated to be approximately 15 Mg per year for 2013. This is below the threshold for installing a GCCS per NSPS Subpart WWW. Tier 2 testing will be required again in 2016 As the required date for operation of the GCCS has not yet occurred, the facility is in compliance with this condition of its permit. The majority of this referenced regulation is not in effect since the non-methane organic compound (NMOC) emission rate is less than 50 Mg per year and the facility is not required to install a landfill gas collection and control system. See below for more details on NMOC generation rate. 2.1.A.Lb. Test Methods and Procedures[I5A NCAC 2D.0524, 40 CFR 60.754] If emission testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0524, 40 CFR _ 60.754 and General Condition JJ. If the results of this test are above the limits given in 40 CFR Part 60, Subpart WWW, the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0524, Subpart WWW i. The Permittee shall calculate the NMOC emission rate using either the equation provided in 40 CFR 60.754 (a)(1)(i) or the equation provided in paragraph 40 CFR 60.754 (a)(1)(ii). Both equations maybe used if the actual year-to-year solid waste acceptance rate is known, as specified in paragraph (a)(1)(i),for part of the life of the landfill and the actual year-to-year solid waste acceptance rate is unknown, as specified in paragraph (a)(1)(ii),for part of the life of the landfill. The values to be used in both equations are 0.05 per year for k, 170 cubic meters per megagram for LO, and 4,000 parts per million by volume as hexane for the CNMOC (A) The Permittee shall compare the calculated NMOC mass emission rate to the standard of 50 megagrams per year. (B) If the NMOC emission rate calculated in paragraph (a)(1) of§60.754 is less than 50 megagrams per year, then the Permittee shall submit an emission rate report as provided in §60.757(b)(1), and shall recalculate the NMOC mass emission rate annually as required under§60.752(b)(1). (C)If the calculated NMOC emission rate is equal to or greater than 50 megagrams per year, then the Permittee shall either comply with 40 CFR 60.752(b)(2), or determine a site-specific NMOC concentration and recalculate the NMOC emission rate using the procedures provided in§60.752(a)(3). (D) The Permittee shall recalculate the NMOC mass emission rate using the equations provided in paragraph(a)(1)(i) or(a)(1)(ii) of 40 CFR 60.754, "Test Methods and Procedures"and using the average NMOC concentration from the collected site samples instead of the default value in the equation provided m paragraph(a)(1) of§60.754 (E)If the resulting mass emission rate calculated using the site-specific NMOC concentration is equal to or greater than 50 megagrams per year, then the Permittee shall either comply with 40 CFR 60.752(b)(2), or determine the site-specific methane generation rate constant and recalculate the NMOC emission rate using the site-specific methane generation rate using the procedure specified in paragraph (a)(4) of 40 CFR 60.754. (F) If the resulting NMOC mass emission rate is less than 50 megagrams per year, the Permittee shall submit a periodic estimate of the emission rate report as provided in 40 CFR 60.757(b)(1) and retest the site-specific NMOC concentration every 5 years using the methods specified in 40 CFR 60.757(b)(1). The required annual report of NMOC emissions was received January 13, 2017. The most recent Tier 2 testing was conducted on September 18,2016. Test results state: EIC ran the Landfill Gas Emission Model(LandGEAI) using the average site-specific NMOC concentration of 235 Buncombe County Landfill II Inspection Report—7/12/17 Page 7 ppmv using parameters required under 40 CFR 60.754(a)(1). The LandGEM results demonstrate that the maximum annual reportable NMOC emissions predicted for the period 2015 through 2019 is 19 MG/yr. By comparison, based on the 2011 Tier 2 testing, the maximum annual reportable NMOC emission predicted for the period 2010 through 2014 was 15 Mg/yr. Based on these results, no further action should be required at this time by the Department under 40 CFR 60 Subpart WWW with regard to installing a landfill gas collection and control system. The test and model results show the NMOC emission rate is well below the 50 Mg/yr that would require compliance with all the elements of NSPS Subpart WWW as indicated above. Additional Tier 2 testing is required every 5 years. New or reconstructed landfills, and modified landfills that increase their design capacity, after July 17,2014 will be subject to NSPS Subpart XXX. This landfill does not appear to subject to Subpart XXX based on the applicability date and will still not be subject to control requirements since the NMOC generation is below the 34 Mg/yr trigger in Subpart XXX. The landfill may be subject to NSPS emissions guidelines (Subpart Cf). However,in a May 5,2017 letter,EPA informed petitioners that it intends to reconsider certain aspects of the 2016 NSPS for the municipal solid waste landfills. The agency has also issued a 90-day stay of the effectiveness of both the NSPS(subpart XXX)and the emission guidelines(subpart Cf). 2.L.A.Lc-Standards For Air Emissions From Municipal Solid Waste Landfills - When the municipal solid waste landfall design capacity becomes equal to or greater than 2.5 million megagrams by mass and 2.5 million cubic meters, with a calculated NMOC emission rate equal to or greater than 50 megagrams per year, the Permittee shall submit a gas collection and control system design plan prepared by a professional engineer who is registered in the State of North Carolina, within one year of the annual report that shows that NMOC emissions will exceed 50 Mg per year: The design capacity exceeds the threshold,but the NMOC emissions are less than 50 megagrams per year. 2.1.A.l.d. Recordkeeping — Except as provided in §60.752(b)(2)(i)(B), the Permittee that is subject to the provisions of§60.752(b)shall keep for at least 5 years, up-to-date, readily accessible, on-site records of the design capacity report which triggered§60.752(b), the current amount of solid waste in place, and the year-by-year waste acceptance rate. Off-site records may be maintained if they are retrievable within 4 hours. Either paper copy or electronic formats are acceptable. Landfill max design capacity: 3.17 million Mg. Current solid waste in place at the end of FY2015:2,255,445 tons. Year by year waste acceptance: Records on site and showed the following during the previous inspection (not observed during this inspection): 2015— 108,388 tons 2014— 114,025 tons 2013— 107,469 tons 2012—109,317 tons 2011 —116,816 tons 2.1.A.Le. - Landfalls subject to the provisions of this subpart shall keep readily accessible documentation of the nature, date of deposition, amount, and location of asbestos-containing or nondegradable waste excluded from collection as provided in§60.759(a)(3)(i)as well as any nonproductive areas excluded from collection as provided in§60.759(a)(3)(U)• 2.1.A.l.f. Annual report— This facility is subject to the requirements of 40 CFR Part 60, Subpart WWW and shall submit an NMOC emission rate report to the Regional Office annually, except as provided for in paragraphs (b)(1)(ii) or(b)(3) of 40 CFR 60.757. If the estimated NMOC emission rate as reported in the annual report to the Administrator is less than 50 megagrams per year in each of the next 5 consecutive years, the Permittee may elect to submit an estimate of the NMOC emission rate for the next 5-year period in lieu of the annual report. This estimate shall include the current Buncombe County Landfill II Inspection Report-7/12/17 Page 8 amount of solid waste-in-place and the estimated waste acceptance rate for each year of the 5 years for which an NMOC emission rate is estimated. All data and calculations upon which this estimate is based shall be provided to the Administrator. This estimate shall be revised at least once every 5 years. If the actual waste acceptance rate exceeds the estimated waste acceptance rate in any year reported in the 5-year estimate, a revised 5-year estimate shall be submitted to the Administrator. The revised estimate shall cover the 5-year period beginning with the year in which the actual waste acceptance rate exceeded the estimated waste acceptance rate. The NMOC emission rate report shall include all the data, calculations, sample reports and measurements used to estimate the annual or 5-year emissions. The Regional Office may request such additional information as may be necessary to verb the reported NMOC emission rate. The required annual report of NMOC emissions was received January 13, 2017. The most recent Tier 2 testing was conducted on September 18,2016. Test results state: EIC ran the Landfill Gas Emission Model(LandGE1L1) using the average site-specific NMOC concentration of 235 ppmv using parameters required under 40 CFR 60.754(a)(1). The LandGEM results demonstrate that the maximum annual reportable NMOC emissions predicted for the period 2015 through 2019 is 19 MG/yr. By comparison, based on the 2011 Tier 2 testing, the maximum annual reportable NMOC emission predicted for the period 2010 through 2014 was 15 Mg/yr. Based on these results, no further action should be required at this time by the Department under 40 CFR 60 Subpart WWW with regard to installing a landfill gas collection and control system. The test and model results show the NMOC emission rate is well below the 50 Mg/yr that would require compliance with all the elements of NSPS Subpart WWW as indicated above. Additional Tier 2 testing is required every 5 years.New or reconstructed landfills, and modified landfills that increase their design capacity, after July 17,2014 will be subject to NSPS Subpart XXX. This landfill does not appear to subject to Subpart XXX based on the applicability date and will still not be subject to control requirements since the NMOC generation is below the 34 Mg/yr trigger in Subpart XXX. The landfill may be subject to NSPS emissions guidelines (Subpart Cf). However, in a May 5,2017 letter,EPA informed petitioners that it intends to reconsider certain aspects of the 2016 NSPS for the municipal solid waste landfills. The agency has also issued a 90-day stay of the effectiveness of both the NSPS(subpart XXX)and the emission guidelines(subpart Cf). 2.1.A.1.g Semi-Annual Summary-The Permittee shall submit a summary report of monitoring and recordkeeping activities by January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar-year for the preceding six-month period between January and June.All instances of deviations from the requirements of this permit must be clearly identified. The most recent semi-annual report was received on 1/13/17 and indicated compliance. 2.1.A.2. S02 from flare-Landfill gas combustion emissions are generally expected to comply with 2D .0516. _ 2.1.A.3.Visible emissions from the flare/20%opacity limit- The main flare was operating with no visible emissions(0%opacity);compliance is indicated. 2.1.A.4. 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS 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. No objectionable odors were noted beyond the property line. GENERATOR ES-GI (Landfill gas-fired engine/generator set,lean burn, 1966 Hp output engine, 1466 kW output) 2.1.B.1.-2D.0516-Landfill gas combustion emissions are generally expected to comply with 2D.0516. Buncombe County Landfill II Inspection Report—7/12/17 Page 9 2.1.8.2. 2D.0521 -Visible emissions from the generator/20%opaci limit—not operating 2 1 B 3 —NSPS Subpart JJJJ-Standards of Performance for Stationary park Ignition Internal Combustion Engines a. The Permittee shall comply with all applicable provisions, including the requirements for emission standards, notification, testing, reporting, record keeping, and monitoring, contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS)" as promulgated in 40 CFR Part 60 Subpart JJJJ, including Subpart A "General Provisions."(15A NCAC 2D.05241 b. The Permittee shall comply with the following emission standards for spark ignition(SI) engines for model year manufactured after July 1, 2010. Stationary spark ignition internal combustion engines shall achieve the required emission standards over the entire life of the engine. Exhaust emission standards: CO: 5.0 g/Hp-hr or 610 ppmvd at 15%Oz NOx: 2.0 g/Hp-hr or 150 ppmvd at 15%Oz VOCs: 1.0 g/Hp-hr or 80 ppmvd at 15%Oz c. If emission testing is required, the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 B. 3. b. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0524. If the SI engine is not certified by the manufacturer to meet the standards in 60.4233(e), an initial performance test to demonstrate compliance with the standards is required. Subsequent performance testing is required every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance. The most recent compliance test was conducted April 4,2017. The test results were reviewed by Brent Hall of SSCB in approved in a memo date June 26, 2017. This memo summarizes the results as follows: GEL Engineeringperformed nitrogen oxides(NO,,), carbon monoxide(CO), volatile organic compounds(VOC), and formaldehyde(CH2O) emissions testing on the Jenbacher(Model J--420 GS-1182, manufactured 2011) landfill gas-fired spark ignition generator unit(1,466 kW, 1,966 horsepower), ES-GL The emissions testing results are acceptable. The formaldehyde testing was requested by NC DAQ via letter dated August 19, 2016 40 CFR 63 Subpart=National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (RICE)requires that the facility comply with 40 CFR 60 Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. The facility was operating under permit No. 10398T01 during testing. Permit condition 2.I.B.5.a establishes State BACT(SB3), as defined in North Carolina General Statute 62-133.8(g) Renewable Energy and Energy Efficiency Por folio Standard(REPS). Per the current permit, the SB3 emission limits for CO,NO.,, and VOC resulting from biomass combustion are the same as the 40 CFR 60 Subpart JJJJ limits. The results of the testing and applicable limits are shown in the table below. Actual Generator Pollutant EPA Test Results Emission Limit Standard Compliance Power Output Method 2.0 g/hp-hr 60 Subpart NO, WE 42.9 ppmvd@15%Oz 150 ppmvd@15%Oz JJJJ Yes 1,363 kW 5.0 g/hp-hr 60 Subpart (93%of CO M10 248.5 ppmvd@15%Oz (610 ppmvd@15%Oz) JJJJ Yes Maximum) 1.0 g/hp-hr 60 Subpart VOC* M25A 11.3 ppmvd@15%Oz Yes (80 ppmvd@15%Oz) JJJJ * VOC is non-methane organic compounds as propane(NMOC as C3H8). Buncombe County Landfill II Inspection Report—7/12/17 Page 10 The formaldehyde emissions averaged 0.072 pounds per hour, or 0.3 tons per year based on 8760 hours of operation. The test results show compliance with NSPS and state only BACT limit. In addition,the formaldehyde emission rate shows the facility to be a HAPs minor source. d. The Permittee shall keep a maintenance plan and records of conducted maintenance and shall, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. An initial Performance test shall be conductedfor NOx, CO, and VOC emissions for engine ES-GI) and the Permittee shall conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance. Maintenance: 10,000 hour maintenance being conducted at the time of inspection;see notes on maintenance earlier in this report. Maintenance activities appear to meet the requirements stated above. e. Stationary spark(SI) ignition internal combustion engines shall meet the following notification, reporting and recordkeeping requirements. i. Keep records of the following information: (A) All notifications submitted to comply with this subpart and all documentation supporting any notification. (B) Maintenance conducted on the engine. (C) If the stationary SI internal combustion engine is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as applicable. (D) If the stationary SI internal combustion engine is not a certified engine or is a certified engine operating in a non-certified manner and subject to§60.4243(a)(2), documentation that the engine meets the emission standards. 2.1.B.4.Pursuant to 40 CFR 63.6590(c)(1), this RICE engine shall meet the requirements of 40 CFR Part 63, Subpart=and Subpart A by meeting the requirements of 40 CFR Part 60 Subpart JJJJ. C. The Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: i. The Permittee shall perform an annual inspection(for each 12 month period following the initial inspection)to ensure the engine is operating properly. ii. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) The date and time of each recorded action; (B) The results of each inspection; (C) The results of any maintenance performed on the engine; (D) Any variance from manufacturer's recommendations, if any, and the corrections made. See maintenance discussion above. Reporting Requirements [15A NCAC 2Q.0508] d. The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ. Buncombe County Landfill II Inspection Report—7/12/17 Page 11 4. Other compliance requirements and issues: a. Title V annual compliance certification—The most recent Title V annual compliance certification for Calendar Year 2016 was received on February 6, 2017 and indicated compliance. Note that the facility is not required to indicate noncompliance for exceeding the state only BACT standard which has since been revised and set equal to NSPS limits. The facility is in compliance with NSPS/BACT limits at this time. b. Semi-annual TV summary report—The most recent semi-annual report was post marked 1/13/17. c. Fugitive dust (15A NCAC 2D .0540) - Sections of the haul roads are paved. Two large tanks are utilized to store groundwater that is applied to the haul roads by a water truck on a regular basis. There is also a sprinkler system that operates on some areas of the haul roads. No fugitive dust emissions were noted. d. MACT Subpart AAAA — National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills-This subpart does not appear to apply at this time. Per previous WNCRAQA inspection: Air Quality Permit No. 11-542-IOA (Part I, Section 2, Condition 2.1(A)(2)) requires the landfill to comply with the requirements of 40 CFR Part 63, Subpart AAAA (once it becomes subject). The Subpart states that a bioreactor is a system where any liquid other than leachate is added in a controlled fashion and that such a system must have a moisture content of at least 40 percent to be a bioreactor. BCSW has been recirculating leachate only; no additional liquids are being added. They have recirculated leachate periodically this year. At this time, the bioreactor does not meet the definition of a bioreactor in Subpart AAAA and 40 CFR 63 Subpart AAAA does not apply to this facility. This Subpart stipulates that the landfill with a bioreactor shall install and operate a landfill gas collection and control system (GCCS) within 180 days after initiating liquids addition or within 180 days after achieving a moisture content of 40 percent by weight, whichever is later. The GCCS must meet the criteria in 40 CFR Part 60, Subpart WWW, Section 60.752(b)(2). In summary, the landfill has installed their GCCS, but they are not required to�operate it at this time. As the required date for operation of the GCCS has not yet occurred, the facility is in compliance with this condition of its permit. Per NCDAQ permit review 12/4/14: 40 CFR Part 63,Subpart AAAA:National Emission Standards for Hazardous Air Pollutants from Municipal Solid Waste Landfalls The Buncombe County Landfill is not Subject to the MACT for landfills because: The landfill is not a major source of HAPs(greater than 10125 tpy), and • The NMOC emission rate from the landfall does not exceed 50 Mg per year, and • The leachate recirculation project at the landfill is not classified as a bioreactor because the landfill only recirculates leachate and does not add any other liquids to the waste to accelerate and enhance the anaerobic(without oxygen)biodegradation of the waste. Per permit: Section 2.2-Permit Shield for Nonapplicable Requirements: [15A NCAC 2Q.0512(a)(1)(B)J The Permittee is shielded from the following nonapplicable requirements. 15A NCAC 2D.I I I I is not applicable to the Municipal Solid Waste Landfill(ES-CI)because the landfill is not required to install a gas collection and control system per NSPS Subpart WWW and the leachate recirculation process at the landfall does not meet the definition of a bioreactor. e. Project XL Leachate Recirculation: "Project XL" information from a previous WNCRAQA Inspection Report: Additionally, the Buncombe County Landfall II is a participant in EPA's Project XL ("eXcellence and Leadership'), a national initiative that tests innovative ways of achieving better and more cost-effective public health and environmental protection. Through this project, the facility is utilizing an alternative liner system while implementing a bioreactor landfall system that involves recirculating landfill leachate. At some time in the future, they may also add liquids other than leachate to the system. Bioreactor systems use controlled methods of liquids addition to increase waste moisture content as a means for promoting decomposition of waste and thus extending the life of the landfill. Federal regulations governing solid waste management restrict liquids addition to only those Buncombe County Landfill II Inspection Report—7/12/17 Page 12 landfills equipped with prescriptive Subtitle D liner systems. The alternative liner system that is utilized at this landfill in Cells 3 through 6 consists of the following: an 18-inch soil barrier layer with a maximum permeability of Ix10-1cm/sec, a geosynthetic clay liner (GCL), a 60-mil HDPE liner and a 24-inch rock drainage layer. For comparison, a traditional composite liner system, which is what is installed in Cells I and 2, consists of a 24-inch soil barrier layer with a maximum permeability 1x10 cm/sec, a 60-mil HDPE liner and a 24-inch rock drainage layer. The EPA project being implemented at this landfill allows the addition of leachate to the cells with the alternative liner system and seeks to determine what impact, if any, liquids addition has on alternative liner systems by comparing the performance of the prescriptive.Subtitle D liner system in Cells 1 and 2 to the alternative liner systems in Cells 3 through 6. The data obtained from this project may provide support for modifying federal regulations to allow liquids addition in MSW landfills equipped with alternative liner systems. Regarding the bioreactor, a retrofit system, which includes wetting trenches, was installed in Cells I through 5 after those cells were filled to capacity. Capability to also extract landfill gas was included in the retrofit system. The system consists of horizontal injection trenches, surficial gravity trenches(SGTs), and vertical wells(vertical wells were actually inserted into the ground horizontally). SGTs are only necessary for the retrofit system. The trenches _ are part of the bioreactor(leachate recirculation)system and the wells are part of the gas collection and control system. This is a dual force main system for gas and leachate. Leachate cannot be circulated while gas is being collected(only one system can operate at a time). A sump riserpulls leachate from the leachatepipe at the bottom of a cell under the gravel layer. In the bioreactor system, leachate is pumped to a leachate pond before being recirculated in the landfill through SGTs, horizontal injection trenches, or vertical wells, which are located above the leachate pipe. In the gas collection system, the gas is piped to a flare unit that was installed in September of 2005 and began operation in 2007. A build-as-you-go wetting system, which means the infrastructure is installed as the waste is being placed, was installed in Cell 6 in July of 2012 and is expected to be operable later in 2013. This type of system, which currently includes 5 lines, will provide better wetting of waste and earlier capture of landfall gas. In November of 2011, BCSW completed construction of a 1.4 MW landfill gas-to-energy project at the site. This project waspermitted in 2009 and included in the Title Vpermit at renewal in 2010. Construction included the installation of 25 vertical gas wells in Cells 1-5. After these wells were put into operation, the gas collection component of the retrofit system was deactivated. Select locations of the retrofit system may be re-activated to collect gas as necessary. A US EPA Project XL stakeholder meeting was held in September of 2012. Project partners, including representatives from EPA,NC DENR, and Buncombe County,participated, as did WNCRAQA, who signed on as a _ supporting signatory to the project in 2000. BCSW's consultant, CDMSmith, went over an update on the project for those present at the meeting. CDM Smith and BCSW provided a 2012 Mid-Year Progress Report, which was attached to the 2012 inspection report. In the report, it is stated that so far, the cells equipped with the alternative liner systems are functioning at a comparable level to those with prescriptive Subtitle D liner systems. While liquids have been observed in the leak detection zones in nearly all of the landfall cells, testing of the liquid indicates it is groundwater. Modifications will be made to the leak detection zones of the future cells to address groundwater intrusion. Since the project began, approximately 2.43 million gallons of leachate has been recirculated, resulting in 485 fewer truck trips to the wastewater treatment plant. That has provided savings of$186,222 in avoided hauling and treatment costs. With the expansion of the leachate recirculation system into Cell 6, the largest cell of the landfall, the amount of leachate that can be recirculated will be significantly increased. It is anticipated that hauling of leachate will not be required outside of the winter season once the Cell 6 system is operational. Leachate is not circulated frequently in the winter months when the temperature(of the leachate) is less than 50 degrees F, as there are concerns that cold water could negatively affect the bacteria that inhabit the landfall. More information about the Buncombe County Bioreactor Project is available at the following website www.buncombebioreactor.coin and in the 2012 report. The landfall is approved by the Climate Action Reserve to register carbon credits for the capture and destruction of methane emitted from the landfall. According to the 2012 Mid-Year Progress Report, the County registered over 2,000 carbon credits in the first half of 2012, which is equivalent to offsetting emissions from 350 passenger vehicles. Landfalls with bioreactors are typically not allowed to sell carbon credits since they are required to operate gas collection and control systems and projects must be voluntary to be eligible for credits. As discussed Buncombe County Landfill II Inspection Report—7/12/17 Page 13 below, this bioreactor does not actually meet the definition of a bioreactor in the EPA rules, and as such, operation of the gas collection and control system is voluntary. Mr. McKenzie stated that they are still not adding any other water source to the leachate recirculation system and they do not meet the EPA definition of bioreactor. He indicated that they are not close to the 40%moisture content required to be classified as a bioreactor. Mr.McKenzie stated that rainfall has the biggest effect in increase the LFG generation rate. During dry periods the LFG generation rate will decline. 5. Based on my observations during this inspection,the Buncombe County Landfill(II) appeared to be in compliance with the applicable air quality regulations and Air Permit No. 10398TO1.