AQ_F_1100542_20180515_ST_RvwMemo

DIVISION OF AIR QUALITY
Technical Services Section
May 15, 2018
MEMORANDUM
To: Brendan Davey, P.E., Asheville Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB)
Subject: Buncombe County Landfill II, Facility ID 1100542, Tracking No. 2016-181ST
Alexander, Buncombe County, North Carolina, Air Permit No. 10398T01
NSPS Subpart WWW, Nonmethane Organic Compounds (NMOC)
Tier 2 Emissions Testing of the Municipal Solid Waste Landfill (ID No. ES-Cl)
For a Site-Specific NMOC Concentration and NMOC Emissions Rate
Performed September 8, 2016 and October 7, 2016 by
Environmental Infrastructure Consulting, PLLC
A report of the subject testing has been reviewed and has been found acceptable for use in
modeling the emissions from the Buncombe County Landfill II. The results appear reliable to
determine the compliance status with respect to the applicable emissions standard.
The emissions standard that applies is 40 CFR 60 Subpart WWW Standards of Performance for
Municipal Solid Waste Landfills. When the Tier 1 NMOC emission rate calculated with the
default values exceeds 50 megagrams per year(Mg/yr), the owner or operator of the landfill
must either install equipment to reduce emissions or conduct Tier 2 testing to determine a
site-specific NMOC concentration. This NMOC concentration value is used when calculating the
annual NMOC emission rate with the equations in 40 CFR 60.754(a)(1). One of the Tier 1
default assumptions is that the NMOC concentration in the gas discharged from the landfill is
4000 parts per million by volume (ppmv)as hexane (C61-114).
The emission rate from the Buncombe County Landfill II exceeds the 50 Mg/yr threshold based
on the Tier 1 default value for NMOC. Therefore, Buncombe County Landfill II conducted Tier 2
sampling to determine the site-specific NMOC concentration for calculation of the annual Tier 2
NMOC emissions rate.
The result of the EPA Method 25C test was 1305 ppmv as methane (CH4). This yields a NMOC
concentration of 217 ppmv as hexane which was further adjusted for air infiltration in accordance
with AP-42 Compilation of Air Pollutant Emission Factors Section 2.4 using Equation 2. After
correcting for the air infiltration, the site-specific NMOC concentration was 235 ppmv as hexane.
The concentration of the nitrogen was added to the Equation 2 denominator since the ratio of N2
to 02 was > 4, indicating air intrusion. The 235 ppmv value was used in the Land GEM
emissions model. The modeled emissions rates are listed in the following table as reported by
Buncombe County Landfill II.
Table 1: 40 CFR 60 Subpart WWW - Buncombe Co nty Landfill II
Emissions Estimated Annual As of January 1 Current NMOC Modeled Tier 2
Year Waste Acceptance Solid Waste-in-place, Emissions NMOC Emissions,
Modeled Rate, (M91Yr) (Mg) Limit, (Mg/Yr) (Mg/Yr) Compliance
2015 103,542- 1,863,300 <50 16.8' Indicated
2016 103,542» 1,966,842 <50 17.3- Indicated
2017 103,542- 2,070,384 <50 17.8- Indicated
2018 103,542" 2,173,925 <50 18.3" Indicated
2019 103,542" 2,277,467 <50 18.8 M Indicated
2020 103,542- 2,381,009 <50 19.2- Indicated
Waste receipts for 2015 and previous years provided by Landfill.
Assuming future waste receipts in years 2016 through 2020.

Brendan Davey, P.E., Asheville Regional Office
May 15, 2018
Page 2 (Buncombe County Landfill II -Site-Specific Tier 2 Landfill NMOC)
Tier 2 Compliance was indicated for the Buncombe County Landfill II for the next 5 years based
on the site-specific NMOC concentration and the annual average waste acceptance rate of
103,542 Mg/yr. The site-specific NMOC concentration should be retested 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 estimate shall be submitted to the Administrator.
If there are any questions concerning this matter, please contact me at(919) 707-8415 or
gregq.oneal(aD_ncdenr.qov.
cc: Booker Pullen, Air Permitting Section
Central Files, Buncombe County
IBEAM Documents - 1100542