AQ_F_1100542_20190411_CMPL_InspRpt (4)

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NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Buncombe County Landfill II
NC Facility ID 1100542
Inspection Report County/FIPS: Buncombe/021
Date: 04/25/2019
Facility Data Permit Data
Buncombe County Landfill II Permit 10398/TOl
81 Panther Branch Road Issued 9/1/2016
Alexander,NC 28701 Expires 11/30/2019
Lat: 35d 43.7295m Long: 82d 38.1522m Class/Status Title V
SIC: 4953 /Refuse Systems Permit Status Active
NAICS: 562212/Solid Waste Landfill Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Kris Smith Dane Pedersen Kris Smith MACT Part 63: Subpart ZZZZ
n t NSPS: Subpart Cf, Subpart JJJJ, Subpart WWW
Solid Waste Manager Buncome Co. Solid Solid Waste Manager
[phone] Waste Director [phone]
[phone]
Compliance Data
Comments:
Inspection Date 04/11/2019
Inspector's Name Christopher Scott
Inspector's Signature: /./� Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: f t_ z � -On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO *HAP
2017 1.68 0.7100 5.18 2.91 12.14 1.68 14459.49
2016 1.59 0.7300 10.31 5.49 31.96 1.59 1879.61
2015 1.69 0.7700 12.32 6.57 32.10 1.69 1594.23
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
07/29/2015 NOWNRE Permit Permit Condition 01/19/2016
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
04/12/2018 Compliance Method 10,Method 25A, Method 7E ES-Gl
Directions: Take 1-26 Nfrom 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 INC 251 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
Suety Equipment:Earplugs and safety shoes.

Buncombe County Landfill
Inspection Report for April 11,2019
Page 2
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 W W W—"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 Y,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
confirmed with Dane Pedersen that this is still the case during a phone conversation on April 12,2019)
On the morning of Thursday,April 11,2019, at approximately 10:30,Mr. Bob Graves and I, Chris Scott met with
Aaron McKinzie,Power Plant Operator to inspect the facility. Kristy Smith,the Bioreactor Manager,had the day
off and Dane Pedersen,the Waste Manager 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 and observe
emissions testing of the landfill gas-fired engine/generator set(ID No.ES-Gl).
1. The following permitted air emission sources and control devices were observed as follows
EMEMM
ES-Cl Municipal solid waste landfill with a leachate CD-GCCSI ** One landfill gas collection
NSPS Subpart W W W 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 scfm maximum
flow rate
The landfill was in operation at the time of inspection,with loading occurring at Cell 6. Area 1 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 acfrn flare was
operating at the time of inspection in part due to the generator being down for maintenance. The 300 acfm 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 acfm 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 acfin and supplies the
generator engine which he states uses about 450 acfm. Any excess gas can be sent to the smaller(300 acfm)flare
which is only supplied by the lower capacity blower skid.

Buncombe County Landfill
Inspection Report for April 11,2019
Page 3
The following data on the flares was recorded during the inspection:
VE not operating
LFG flow to flare 1 0
LFG flow to flare 2 0
LFG flow to generator 438 scfm
flare 1 LFG total 121.04 mmSCF
flare 2 LFG total 3 5.2 8 mmSCF
total runtime—flare 1 12,571 hours
total runtime—flare 2 897 hours
combustion temp—flare 1 not operating
combustion temp—flare 2 not operating
vacuum notrecorded
From aprevious 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. Asa 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 of2011 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 j
additional details.
Y
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 f
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 genet 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
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 I
• thermocouple on intake replaced
• replacing?vibration dampeners
• checking air intake louvers

Buncombe County Landfill
Inspection Report for April 11,2019
Page 4
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:
OMMMEMEM
VE 0% 0%
Power output 1,295-1,305W 1355 to 1365 kW 1351 kW
kW being produced) setpoint: 1300 kW setpoint: 1360 kW setpoint: 1350 kW
Total volume 1,420.74 mmSCF 1,124.5 mmSCF 767.77 mmSCF
since began operation) includes previous engine) includes previous engine) includes previous engine)
Fuel(LFG)flow 367 scfin 438 scfm 400 scfm
(generator gas flow
Fuel pressure 4.9 psi at blower;49.3%of 4.9 psi at blower;49.3%of 4.9 psi at blower;49.3%of
range range range
LFG data(analyzer at CH4=55.9% CH4=50.1% C144=54.7%
blower) 02=0.78% 02=0.7% 02=0.59%
total engine operating 24,155 hours 16,430 hours 1,056 hours
hours
Engine speed 1800 rpm(has to be this RPM to generate electricity at 60 Hz
%methane and oxygen 55.8%and 0.7% 51.3%and 1.7% 53.2/53.5%and 0.0%
Combustion temp flare n/a n/a n/a
Avg. exhaust temp. 575 551°C 5740C
#of starts since installation 313 not noted 152
Blower skid data inlet vacuum=8.1" inlet vacuum= 13.9" inlet vacuum=6.9"
LFG temp. =77 OF LFG temp.=690F LFG temp. =690F
LFG pressure=4.9 psi LFG pressure=4.9 psi LFG pressure=4.9 psi(?)
LFG flow=365 scfm LFG flow=425 scfm LFG flow=398 scfm
max capcity=500 scfm per max capcity=500 scfm per max capcity=500 scfm per
late 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 141h. 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
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 Ffor 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 14'. Methane and oxygen sensors were not operational. Mr. McKinzie

Buncombe County Landfill
Inspection Report for April 11,2019
Page 5
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 24t6, 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:
IES-TGl 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 landfill, on the site, or to the maintenance area. It mounted on a skid with
wheels.
it
Per a previous WNCRAQA 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 exemptfrom 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 insignificant 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 I On leachate pond 30,000 square feet of surface area, 1,000,000 gallon capacity)-not observed.
3. Compliance with specific permit conditions and limitations:
GAS SYSTEM WITH FLARE
2.1.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 landfill 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 of2011. 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

Buncombe County Landfill
Inspection Report for April 11,2019
Page 6
controls stem. See below for more details on NMOC generation rate.
2.1.A.1.b. Test Methods and Procedures[15A 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§60.75 7(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)(it) of40 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
in paragraph(a)(]) 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 25,2019. The most recent Tier 2 testing
was conducted on September 18,2016. Test results state:
EIC ran the Landfill Gas Emission Model(LandGEM) using the average site-specific NMOC concentration of 235
ppmv usingparameters 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 MGlyr. By
comparison, based on the 2011 Tier 2 testing, the maximum annual reportable NMOC emission predicted for the
period 2010 through 2014 was 15 Mglyr. 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 C .
2.L.A.l.c-Standards For Air Emissions From Municipal Solid Waste Landfills- When the municipal solid waste
landfill 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

Buncombe County Landfill
Inspection Report for April 11,2019
Page 7
submit a gas collection and control system designplan prepared by aprofessional 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 me a rams per year.
2.1.A.l.d.—Recordkeeoing—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 ofsolid waste in place, and the year-by-year waste
acceptance rate. Off-site records maybe maintained if they are retrievable within 4 hours. Either paper copy or
electronic formats are acceptable.
Landfill max design capacity: 8.8 million Mg. Current solid waste in place at the end of FY2018: 2,397,082 tons.
Year by year waste acceptance(based on annual reporting;not observed during this inspection):
2014— 113,247 tons
2015— 113,896 tons
2016— 103,145 tons
2017— 130,411 tons
2018—130,220 tons
i
2.1.A.I.e. -Landfills 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 excludedfrom
collection as provided in§60.759(a)(3)(1) as well as any nonproductive areas excludedfrom collection as provided
in§60.759(a)(3)(ii).
2.I.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
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 maybe
necessary to verb the reported NMOC emission rate.
The required annual report of NMOC emissions was received January 25,2019. The most recent Tier 2 testing
was conducted on September 18,2016. Test results state:
EIC ran the Landfill Gas Emission Model(LandGEM) 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 W W W as indicated above. Additional Tier 2 testing is required '..

Buncombe County Landfill
Inspection Report for April 11,2019
Page 8
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 C .
2.1.A.l.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 January 25,2019, 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 not operating at the time of this inspection.
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.
2.1.B.2.—2D.0521 -Visible emissions from the generator/20%opacity limit—not operating
2.1.B.3.—NSPS Subpart JJJJ- Standards of Performance for Stationary Spark 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."[I5A NCAC 2D.0524]
b. The Permittee shall comply with the following emission standards for spark ignition(SI) engines for model year
manufactured after July], 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 g1Hp-hr or 610 ppmvd at 15%OZ
NOx 2.0 g/Hp-hr or 150 ppmvd at 15%OZ
FOCs: 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 ofthis 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 12,2018. The test results were reviewed by Gregg O'Neal of Stationary Source Compliance Branch
(SSCB)and approved in a memo date September 11,2018. This memo summarizes the results as follows:

I
Buncohibe County Landfill
Inspection Report for April 11,2019
Page 9
GEL Engineering performed the subject testing on the Jenbacher(Model J-420 GS-B82, Manufactured 2011)landfill
gas fired spark ignition generator unit(1,466 kW, 1,966 horsepower), ES-GI. SSCB has reviewed the testing and the
results are acceptable.
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.
Permit condition 2.1.B.5.a establishes State BACT, as defined in North Carolina General Statute 62-133.8(g)
Renewable Energy and Energy Efficiency Portfolio Standard(REPS). According to the current permit the State
BACT emission limits for CO and NOx resultingf•om biomass combustion are the same as the 40 CFR 60 Subpart
JJJJ limits.
' l 151' �I}�� 1 � kF � I�li�y� i � � i � •i d
State BACT
NO.
WE57.507mvd15 02 or150 2.0
m�vd 15%Oz Indicated
1,355 kW PP@ ( PP @ ) 60 Subpart JJJJ
92%of 2.6 g/HP-hr 5.0 g/HP-hr State BACT
Maximum CO M10 337 ppmvd@15%02 (or 610 ppmvd@15%Oz) 60 Subpart JJJJ Indicated
VOC* M25A 0.28 g/HP-ha 1.0 gtHP-hro 60 Subpart JJJJ Indicated
23.6 ppmvd@15/o Oz (or 80 ppmvd@15/o Oz)
*VOC as non-methane organic compounds as propane(NMOC as C3H8).
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.
L
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 conducted for 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
comesfirst, 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. Ili
1. 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.I.B.4.Pursuant to 40 CFR 63.6590(c)(1), this RICE engine shall meet the requirements of 40 CFR Part 63,
Subpart ZZZZ 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:

Buncombe County Landfill '
Inspection Report for April 11,2019
Page 10
1. 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.
Reyortin2 Requirements [15A NCAC 2Q .05081
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.
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 (Part1, 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 controlledfashion 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 landfall 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 Landfills
The Buncombe County Landfill is not Subject to the MACT for landfills because:
The landfill is not a major source ofHAPs(greater than 10125 ipy), and
The NMOC emission rate from the landfill does not exceed 50 Mg per year, and
The leachate recirculation project at the landfall is not classified as a bioreactor because the
landfill only recirculates leachate and does not add arty other liquids to the waste to accelerate and enhance the
anaerobic(without oxygen) biodegradation of the waste.

Buncombe County Landfill
Inspection Report for April 11,2019
Page 11
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.III 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 landfill does not meet the definition of a bioreactor.
F
e. Project XL—Leachate Recirculation: "Project XL"information from a previous WNCRAQA Inspection Report:
Additionally, the Buncombe County Landfill 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 landfill 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
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-Scm/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 1 and 2, consists of a 24-inch
soil barrier layer with a maximum permeability Ix10-'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 I 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 1 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 k
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 riser pulls leachate from the leachate pipe 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 ofsystem, which currently includes 5 lines, will provide better wetting of waste and earlier capture of landfill
gas.
In November of 2011, BCSW completed construction of a 1.4 MW landfill gas-to-energy project at the site. This
project was permitted in 2009 and included in the Title V permit at renewal in 2010. Construction included the
installation of25 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 maybe re-activated to
collect gas as necessary.
A US EPA Project XL stakeholder meeting was held in September of2012. 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, CDM Smith, went over an update on the project
for those present at the meeting. CDMSmith 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 landfill 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

Buncombe County Landfill r '
Inspection Report for April 11,2019
Page 12
the landfill, 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 landfill. More information
about the Buncombe County Bioreactor Project is available at the following website www.buncombebioreactor.coin
and in the 2012 report.
The landfill is approved by the Climate Action Reserve to register carbon credits for the capture and destruction of
methane emitted from the landfill. 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. Landfills 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
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.
Stack Test Notes and Observations -The stack test was being conducted to satisfy the NSPS requirement to conduct
a performance test within 3 years or 8,760 hours of operation(Because the engine runs continuously, the
performance test is tested every year). S133 BACT limits have been set equal to NSPS limits;therefore,the test will
indicate compliance with both. The analyzers were being run and calibrated by Kirk Alexander, Senior Project
Manager of Gel Engineering LLC of Charleston, SC. Contact information for Kirk Alexander is as follows:
Kirk Alexander,QSTI 2040 Savage Road
Senior Project Manager Charleston, SC 29407
akaggel.com phone: [phone] fax: [phone]
PO Box 30712 cell phone: [phone]
Charleston, SC 29407 www.gel.com
We observed the second run and the end of run leak checks. The dilution system was an Environics Series 4040
(S/N 2983). The analyzer was Servomex 4900 Muiltigas.
02 8.09% 8.11%
CH4 733.8 ppin 724.3 ppm
THC 805.5 ppm 800.4 ppm
NOx 104.5 ppm 105.9 ppm
Introduce zero and high to calibrate,then introduce low and mid to check: Yes
Heated sample line:Yes—280 F
In stack filter used:Yes
Is a gas dilution system is used? Yes
If so,request the gas dilution system calibration be submitted with the test report? Yes
Sample conditioner/dryer used?Yes
Sample system flow rates within 10%of calibration flow rates? Reported to be equal.
Digital data recorder used. Yes
System bias check performed for each analyzer before the first run,between each run?Yes
Total NOx being analyzed?Yes(NO+NO2)
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. 10398T01.

Buncombe my Genera G1 4/11119
CO, NOx, (CO2&VOC
Run 1
Time NOx ppm CO2 (%) THC ppm CH4 ppm 02 % CO ppm
9:04:33 103.3 10.47 834.2 781.9 8.1 559
9:05:33 102.8 10.48 813.2 758.6 8.09 560.7
9:06:33 103.4 10.48 801.3 742 8.08 561.5
9:07:33 104 10.48 796.7 742.7 8.08 559
9:08:33 104.2 10.47 821.2 751.3 8.09 560.1
9:09:33 104.2 10.48 803.4 743.6 8.08 560.3
9:10:33 104.6 10.47 812.6 748.9 8.09 559.2
9:11:33 104.6 10.47 817.9 748.6 8.1 558.8
9:12:33 103.9 10.47 824.4 742 8.09 559.7
9:1333 103.1 10.48 794.7 0
8.1 558
9.15:33 1 311Z5 743.9 8.09 -94
9:16:33 103.4 10.49 814.4 742.1 8.09 558
9,17,33 103.5 10.49 806.9 729.7 8.08 559.6
9:18:33 103.3 10.49 806.4 732.7 8.08 560
9:19:33 103.8 10.49 813.8 734.2 8.08 558.7
9:20:33 104.4 10.48 815.7 745.1 8.09 559.8
9:21:33 104.7 10.49 814.8 741.3 8.09 559.3
9:22:33 104.8 10.48 826.5 746 8.08 559.9
9:23:33 1042 10.48 805.7 747.2 8.1 560.7
9:24:33 103.1 10.48 810.7 730.1 8.09 561.3
9:25:33 103.7 10.48 819.1 743.4 8.09 559.2
9:26:33 104.1 10.48 816 737 8.09 558
9:27:33 103.2 10.48 816.3 736.5 8.1 558.5
9:28:33 102.9 10.49 802.2 739.1 8.1 559
9:29:33 103.7 10.49 806.8 733.9 8.09 561.8
9:30:33 104.7 10.48 797.9 735.5 8.09 559.1
9:31:33 105 10.48 816.1 735.9 8.1 560.7
9:32:33 104.6 10.48 808.6 733.9 8.09 560.7
9:33:33 104.5 10.48 804.8 734.4 8.09 561.2
9:34:33 104.4 10.48 799.4 735.2 8.1 558.5
9:35:33 104.2 10.49 7812 726 8.09 558.1
9:36:33 104.8 10.49 800.2 723.8 8.08 559.7
9:37:33 104.9 10.49 806.4 733.4 8.09 559.1
9:38:33 104.8 10.49 806.8 731 8.09 560.5
9:39:33 104.9 10.49 801.4 721.5 8.08 562
9:40:33 105 10.48 812.3 738.6 8.09 561
9:41:33 104.6 10.49 794.6 731.7 8.09 559.1
9:42:33 104.8 10.49 807.8 727 8.08 560.8
9:43.33 105.1 10.49 807.3 734.7 8.09 562
9:44:33 104.2 10.49 822.7 740.1 8.09 561.3
9:45:33 104.2 10.49 792.4 720.8 8.08 561.7
9:46:33 105.2 10.49 788.3 721.7 8.08 562.1
9:47:33 105.5 10.49 804.9 732.8 8.08 560.1
9:48:33 105.6 10.49 786.3 714.3 8.08 562.7
9:49:33 105.9 10.49 793.6 723.3 8.08 562
ill

i
9:50:33 106 10.49 794.2 717.6 8.07 561.7
9:51:33 105.3 10.49 798.8 722.4 8.08 562
9:52:33 105.2 10.49 806 726 8.08 560
9:53:33 105.9 10.5 762.8 705.6 8.08 560.6
9:54:33 105.8 10.49 793 716.5 8.08 562.3
9:55:33 105.3 10.48 794.9 721.8 8.09 559.1
9:56:33 105.6 10.49 808 730.5 8.08 560.8
9:57:33 105.9 10.49 792.3 719.2 8.08 560.3
9:58:33 105.7 10.49 800.5 723.7 8.08 559.4
9:59:33 105 10.48 799.9 718.4 8.09 559.9
10:00:33 105.1 10.48 785.7 723.4 8.1 560.5
10:01:33 105.1 10.49 809.5 723 8.09 558.2
10:02:33 105.1 10.48 813.8 733 &1 559.9
10:03:33 104.7 10.49 820.1 730 5�!,( .! ..8-09 562.2
M 5.5r;,�
AVG 104L5 1B §QA` 109 560.2
1
14
{
I
l

Buncombe my Generr.G1 4/11119
CO,NOx,(CO2&VOC
Run 2
Time NOx ppm CO2(%) THC ppm CH4 ppm 02% CO ppm
10,11:09 103.8 10.48 803.1 719.7 8.08 560.4
10:12:09 104.4 10.48 806.7 725.8 8.09 558.5
10:13:09 104.8 10.49 796.2 721.5 8.08 559.8
10:14:09 105.4 10.49 782.9 710 8.08 560.8
10:15:09 105.9 10.5 792.8 707.5 8.08 560
10:16:09 106.2 10.49 798.8 725.2 8.08 559.5
10:17:09 106.2 10.5 816.3 726.3 8.07 561.4
10:18:09 105.8 10.51 776 722.9 8.07 562.8
10:19:09 106.6 10.5 789.7 709.8 8.07 560.4
10:20:09 107.4 10.49 791.6 711.2 8.07 561.7
10:21:09 106.4 10.48 828.7 728.3 8.09 561.7
10:22:09 104.9 10.48 797.4 736.8 8.1 560.9
10:23:09 104 10.49 800.6 732.7 8.09 561 Ir
10:24:09 103.9 10.49 795.6 719.7 8.09 559.8 .
10:25:09 103.7 10.49 800.2 725.1 &08 559.5
10:26:09 103.7 10.49 792.4 717.7 8.09 561.1 I.
102709 103.9 10.49 796.4 718.3 8.09 560.2
10:28:09 104.2 10.49 817.4 737.3 8.09 559.6
10:29:09 104.6 10.5 787.8 727.6 8.09 562.9
10:30:09 105.5 10.48 785.2 719.7 8.08 560.4
10,31:09 106.4 10.46 791.5 713.3 8.11 559.7
103209 106.7 10.46 793.9 722.1 8.12 560
10:33:09 105.5 10.46 777.1 718.8 8.13 558.1
10:34:09 104.8 10.46 797 714.8 8.12 561
10:35:09 105.1 10.47 798.1 716.5 8.12 561 A
1036,09 105.7 10.48 798.5 727.5 8.11 560.4
103709 107 10.48 801.8 712.2 8.1 560.5
10:38:09 107.8 10.49 772.2 718.6 8.1 561.1
10:39:09 108.2 10.49 796.2 701.1 8.09 561.3
10,40,09 108.2 10.48 782.6 714.5 8.1 559.4 4
10:41:09 108.1 10.47 785.7 707.1 8.11 560.5
10:42:09 106.4 10.47 792.8 713.5 8.11 559.7
10:43:09 104.8 10.47 804.3 727.7 8.11 562.5
10:44:09 104.9 10.48 829.2 735.7 8.11 562.6
104509 106.8 10.47 816.5 734.7 8.12 562.4
10:46:09 107.1 10.47 809.7 740.8 8.12 560.4
10:47:09 105.7 10.48 805.6 728.9 8.11 558.1 -
10:48:09 105.2 10.47 811.4 723.1 8.11 556.3
10:49:09 105.9 10.48 798.6 720.2 8.11 559.8
10:50:09 106.4 10.47 818.5 727.7 8.12 559.4
10:51:09 106 10.48 816.1 725 8.12 560.3
10:52:09 105.3 10.47 815.7 736.1 8.12 561.3
10:53:09 105.3 10.47 822.1 728.3 8.12 558.8
10:54:09 105 10.46 830.4 746 8.13 558.1 f
10:55,09 104.6 10.48 800.5 732.5 8.13 559
10:56:09 104.6 10.48 805.5 731.8 8.11 560.8
10:57:09 106.5 10.48 820.5 729 8.11 560.2
10:58:09 107.5 10.47 813.3 739.8 8.12 560.2 i.
10:59:09 106.6 10.47 820.8 740.9 8.13 559.1
11:00:09 105.7 10.47 797.4 726.7 8.12 558.9
1101:09 105.6 10.47 795.6 733.9 8.12 559
11:02:09 105.9 10.48 798.9 730 8.12 558.5
11:03:09 105.9 10.48 797.6 727.3 8.11 558.8
11:04:09 106.4 10.47 797.1 731.8 8.12 559.5
11:05:09 107.2 10.48 794.6 725.3 8.12 558.4 'r
11:06:09 107.9 10.48 790.6 718.4 8.12 558.3
110709 108.2 10.47 798.4 726.8 8,13 558.1
11:08:09 107.4 10.47 785.5 723.6 8.13 556.9
11:09:09 107.1 10.48 797 724.8 8.12 559.5
11:10:09 107.3 10.47 787.1 719.4 8.13 558.4
AVG 105.9 10.48 800.4 724.3 8.11 560.0
III

EPA Method 2 - Velocity Data Sheet
Plant/Client Date
Plant Site Run Number 1
Sampling location Project Number
Stack Dimensions Observer
GEL Test Personnel Agency
Data
Barometric Pressure(in.Hg) Pitot ID Number
Static Pressure(in.H2O) Pitot Type
Manometer Number Pitot Coefficient
Pitot Tube Leak Check(Pretest) Pitot Tube Leak Check(Post test)
Pre Test LC Side A B Post Test LC Side A B
Pressure Tap (in.H2O) Pressure Tap (in.H2O)
Stable for 15 sees?(Y/N) Stable for 15 secs?(Y/N)
Velocity Data ORSAT Data
Start Time Sampling Analysis %CO2 %02 %CO %N2
Stop Time Time Time Reading Reading (If Taken)
Point Sample (A) (B) (C) (100-A-B-C)
AP Temp.
Number Point
°F
1
2 Bag No. IPump No.
3 Moisture Data (Wet Bulb/Dry Bulb)
4 Port Time Dry Bulb Wet Bulb Psychomet. Bws
5 Reading Reading Ib Hz0/lb air
6 °F °F X (%H20)
7
s
9
10
11 Moisture Data (Method 4)
12 Start Time Initial Wgt of H2O(9)
13 Stop Time Final Wgt of H2O(g)
14 Time(minutes) Wgt ofH2O(g)
15 Initial DGM Vml) Initial Wgt of Silica(g)
16 Final DGM(Vmf) Final Wgt of Silica (g)
17 Volume(Vmf-Vmi) W t of Silica(g)
1S Meter Box Number Total Wgt Gain )
19 Meter Box Gamma Avg DH(in. H20)
20 Initial DGM Temp,Tm Post Leak Rate(ft'/min)
21 Final DGM Temp,Tm I I Bws
22 Thermocouple Calibrations
23 Nist Thermometer#
24 Reference Temperature(°F) Probe Temp(°F)
AVG DGM(°F)
GEL Engineering,LLC
A Member of The GEL Group,1.c.
2040 Savage Road,P.O.Box 30712,Charleston,S.C. 29407
Phone[phone] FAX[phone]

Operator log for 2017
1-4 changed oil per oil analysis 6163 oph
1-5 pumped condensate out of header
1-11 took oil sample
1-17 changed spark plugs 6470 oph
1-24 mains breaker trip
1-31 took oil sample
2-8 greased alternator at 7001 oph
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2-16 oil sample, added 2 drums to make up tank, bearings in old flare replaced.
2-27 knock shutdown#10 on restart from pumping out gas line
3-1 oil sample at 7494 oph, changed cabin filters
3-7 changed #10 spark plug
3-13 changed oil, replaced cap on gw20
3-22 measured valve recession
3-27 decoke at 8108 oph,4000 oph service also performed
3-31 voltage regulator replaced
4-4 emissions test
4-25 added 2 drums to makeup tank,took oil sample.
5-13 oil filter changed
5-15 got both old and new flare running at the same time
5-19 mains breaker trip
5-24 changed oil air filter pumped condensate out of gas line
6-8 pass2 onsite to calibrate flare flow meters
6-30 gas inlet temp change too fast . Odd alarm most likely caused by gas quality dropping due to
running old flare .Will leave old flare off until gas quality returns
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7-10 synch failure
7-11 10K hour service
7-14 cylinders were scoped revealing siloxane deposits water in gas to blame. Muffler has hole rusted
through it.
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7-20 throttle valve actuator failure
8-5 french broad mains breaker trip
8-7 decoke turbo and intercooler replaced
8-19 change oil filter
8-29 pass2 onsite to calibrate flare flow meters.
9-12 mains breaker trip
10-1 mains breaker trip, replaced throttle valve linkage
10-25 changed oil and spark plugs
11-27 cylinder temp hi shutdown
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12-18 replaced starters
12-29 vfd fault on blower skid
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11-16 ordered parts for air dryer
11-20 added oil to makeup tank
11-21 measured valve stems for side slope expansion, B&P onsite to fix air compressor
12-13 air dryer in garage installed
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Operator log for 2018
1-26 pulled pump cell 2
1-29 1200 gal removed from cell 2
2-28 replace pump cell 2
2-12 ordered air regulators for 5 pumps
2-14 dewatered vault box cells 2 and 3
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2-22 hi oil temp alarm,control screen froze rebooted plc
3-15 fix leaking oil discharge hose
3-21 received parts from Nixon not sent earlier per contract
3-22 found leak hit 6b tightened screws and replaced caps on all wells
3-23 Removed well heads from gas 6b and hit6e, added %tank to makeup oil
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3-29 patched muffler f
3-30 replaced batteries, spark plugs and air filter
4-10 nixon set leanox
4-12 emissions test
4-17 oil sample
4-19 restarted generator, installed pump cell 1, air compressor hi discharge temp shutdown.
4-22 b&p serviced air compressor
4-24 fix cell 1 pump
4-27 pass2 onsite to calibrate flow meters on flare
5-8 restart generator
5-17 pass2 onsite to fix old flare flow meter
6-15 hi oil temp shutdown
6-29 thermostats and cooling fan changed
6-30 hi oil temp shutdown
7-17 nixon onsite to fix issue with 4 out of 8 cooling fans running
7-25 clean radiators and oil cooler
8-1 contacted b&p to fix hi discharge temp/oil consumption problem
8-2 mikes septic onsite to pump lecahte out of ditch took oil sample @ 18767 oph

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8-7 cleaned cooling tower, Mains breaker trip.
8-10 cleaned cooling tower, added oil to makeup tank
8-13 propane tank for flare was filled
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8-16 replacement muffler arrived damaged, load was refused
8-24 added 1/8 tank to makeup tank
8-30 changed cabin filters
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8-31 cleaned cooling tower
9-4 took ail sample @ 19550, put 1/8 tank in makeup tank
9-7 changed oil,oil filter and spark plugs
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9-10 added oil to makeup tank, mains breaker trip
10-1 generator shutdown for 20K service, a top end rebuild
10-2 b side manifold was found to have small crack was later determined that it will be fixed at a later
time
10-3 replaced sparking transformer on flare
10-8 generator still down for service oil cooler was swapped out on this day. C
10-12 generator back online
10-18 sparker on flare was found to be stuck on, it was powered down to trouble shoot
10-22 sparker on flare was found to be working correctly, decided to leave powered down unless
needed.
10-31 powered off generator and started flare for raising of gas wells,throttle valve linkage broke on
shut down
11-1 fixed throttle valve linkage and found it's controller to be bad. j
11-5 replaced throttle valve controller and linkage,still didn't start due to gas train failure alarm.
11-7 generator back online gas train failure alarm was bypassed awaiting parts.
11-13 replaced gas safety device, did not solve issue.
11-14 added oil to makeup tank
11-26 sampled oil at 21098 oph
11-29 added oil to makeup tank
12-7 greased motor and blower
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