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' Franklin Engineers&Consultants,LLC.Frank,11 ion 2734 Sunrise Blvd,Suite 308
Pearland,TX 77584
Engineers&Consultants.LLC. Phone: [phone]
March 17,2020 RECEIVED
Mr.Mitchell Revels,Chemist
NC Department of Environmental Quality-Air Quality
225 Green St#714 AA 1 8 242D
Fayetteville,NC 28301
Division of Air Quality
RE: RY2019 Annual NMOC Emission Rate Report Fayetteville Regional Office
Anson County Waste Management Facility
Title V Permit No.09835T04;Facility ID No.0400052
Dear Mr.Mitchell Revels:
On behalf of Chambers Development of North Carolina, Inc. (WCN), Franklin Engineers&Consultants,LLC. (FE&C) is
pleased to submit the attached RY2019 Annual NMOC Emission Rate Report for the Anson County Waste Management
Facility(ACWMF)located in Polkton,NC.
The procedures specified in 40 CFR 60.754(a) (Method A) and 40 CFR 60.754(b) (Method B) were used to recalculate
the NMOC emission rate for ACWMF. This annual report has been prepared based on the results of the most recent Tier
2 Test conducted on December 27, 2018.1 In accordance with the USEPA Determination letter included as Attachment A
of this report, the Annual NMOC Emission Rate Report for RY2019 must be submitted to the NCDEQ no later than
March 31, 2020. Based on this NMOC Emission Rate Calculations included as Attachment B of this correspondence, the
RY2019 NMOC Emission Rate is projected to be 26.14 Mg/yr.
At this time,ACWMF is not required to install a Landfill Gas Collection and Control System because the NMOC
emission rate is currently less than 50 Mg/yr. If the actual NMOC emission rate remains below 50 Mg/yr through 2022,
WCN will perform a Tier 2 Test Update in December 2023.
Should you have any questions concerning the attached report, please call Lana Brown at [phone] or Juene
Franklin at 832-244-1980.
Sincerely,
Franklin Engineers& Consultants, LLC.
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Juene Franklin,P.E.
President
Attachment: Attachment A—USEPA Region 4 Method B Approval Letter
Attachment B—RY2019 NSPS Annual NMOC Emission Rate Calculations
Attachment C—Responsible Official Statement of Certification
cc: w/attachment
Nelson Breeden-Waste Connections, Inc.Eastern Region Engineer(Electronic)
Lana Brown—Waste Connections,Inc.Eastern Region Environmental Compliance Specialist(Electronic)
Tyler Fitzgerald-Chambers Development of North Carolina,Inc. Site Manager
'It is important to note that one of the field samples from the test conducted on December 27,2018 did not satisfy the oxygen/nitrogen criteria of the
NSPS;therefore,a follow-up test was conducted on January 31,2019 to obtain one(1)additional valid sample.

ATTACHMENT A
USEPA REGION 4 METHOD B APPROVAL LETTER

SEv stq,:s
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
>w REGION 4
a ATLANTA FEDERAL CENTER
i 61 FORSYTH STREET
41 SSE°� ATLANTA, GEORGIA 30303-8960
Nov 18 2015
Sean Alteri, Director
Division of Air Quality
Department of Environmental Protection
KY Natural Resources &Environmental
Protection Cabinet
200 Fair Oaks Ln., 1"Floor
Frankfort, Kentucky 40601
Dear Mr. Alteri:
The purpose of this letter is to provide you with guidance regarding the enclosed August 24, 2015,
correspondence in which Franklin Engineers and Consultants(FE&C)submitted non-methane organic
compound(NMOC)emission rate calculations for the Hopkins County Regional Landfill (HCRL)
located in White Plains, Kentucky.The U. S. Environmental Protection Agency Region 4 reviewed
FE&C's submittal and has determined that the approach used for calculating the NMOC emissions rate
for a portion of the landfill which is equipped with an existing gas collection and control system(GCCS)
is acceptable. Details regarding the calculations and the basis for our conclusions are provided in the
remainder of this letter.
The HCRL is subject to NMOC emission limits in 40 Code of Federal Regulations (CFR) Part 60,
Subpart WWW—Standards of Performance for Municipal Solid Waste Landfills. Under these
regulations,owners and operators of affected facilities whose NMOC emission rate is less than 50
megagrams per year(Mg/yr) are required to report the landfill's emission rate annually. Within twelve
months after submittal of the first annual report demonstrating that the NMOC emission rate from a
landfill is 50 Mg/yr or greater,owners or operators must submit a design plan for a GCCS, and the
system must be installed and operational within 30 months after submittal of the first report
demonstrating that the landfill's NMOC emission rate is 50 Mg/yr or greater.
Two equations used for calculating landfill NMOC emission rates to satisfy the annual reporting
requirement are promulgated at 40 CFR §60.754(a)(1). In their most basic form, these equations use
default values for the NMOC concentration in the landfill gas and the landfill methane generation rate
constant. Although using these default values makes it relatively easy to calculate NMOC emission
rates, the default values are based upon conservative assumptions that tend to overstate emissions. For
this reason, landfill owner/operators also have the option to conduct sampling to determine site-specific
NMOC concentrations and/or methane generation rate constants.The sampling for determining a site-
specific NMOC concentration is referred to as Tier 2, and the sampling for determining a site-specific
methane generation rate constant is referred to as Tier 3.
Between September 23, 2014, and October 1, 2014,Tier 2 testing was conducted at the HCRL. Samples
to determine the NMOC concentration in a ten acre section of the landfill that is under the influence of
an existing GCCS were obtained from the collection system header, and the average NMOC
concentration measured in this portion of the landfill was 119 parts per million by volume (ppmv). This
Internet Address(URL)•http://www.epa.gov
Recycled[Recyclabie•Printed with Vegetable Oil Based Inks on Recycled Paper(Minimum 30%Postconsumer)

value is well below the default value of 4000 ppmv used for calculating NMOC emission rates using the
equations in 40 CFR §60.754(a)(1).
When calculating the NMOC emission rate for the portion of HCRL under the influence of the GCCS,
FE&C used an equation in 40 §CFR 60.754(b). Under Subpart WWW the stated purpose for the
equation in 40 CFR §60.754(b) is to provide a way of determining when the NMOC emission rate at a
closed landfill has dropped below 50 Mg/yr so that a GCCS can be removed.The FE&C decision to use
the equation in 40 CFR §60.754(b)to calculate the NMOC emission rate for the portion of the landfill
under the influence of the GCCS is based upon guidance provided in Section IV.B.4 in an EPA
document entitled Municipal Solid Waste Landfill New Source Performance Standards and Emission
Guidelines—Questions and Answers.This guidance document was initially published in 1998 and was
revised in 2002.
The response to question IV.B.4 in EPA's revised guidance document indicates that NMOC emission
rates for landfills that have an existing GCCS can be determined by measuring the NMOC concentration
in the collection system header and entering these results in the equation from 40 CFR §60.754(b).The
response goes on to say that the equations in 40 CFR §60.754(a)(1)can also be used in the emission rate
calculation when Tier 2 sampling is conducted from the GCCS header.
When FE&C used the equation in 40 CFR §60.754(b)to calculate the emission rate for portion of the
landfill with a functioning GCCS, it relied on the NMOC concentrations measured during the Tier 2
sampling conducted in 2014 and the total volume of landfill gas metered at the flare inlet during 2014.
The decision to use the total metered volume of gas for the year was based upon a recommendation from
EPA Region 4, and the premise behind EPA's recommendation is that the total measured flow to the
flare over an entire year will be a more reliable indicator of the system's annual flow rate than a flow
rate extrapolated from short-term data.
S
Our conclusion regarding the acceptability of the approach FE&C used for calculating the NMOC
emission rate for the portion of the HCRL under the influence of the GCCS is based upon two factors.
The first of these factors is that the approach is consistent with current EPA guidance regarding the
implementation of Subpart WWW.The second of these factors is that the equation in 40 CFR
§60.754(b) is likely to yield a more accurate NMOC emission rate result than the equation in 40 CFR
§60.754(a)(1)because it uses volumetric flow rates that are measured directly,rather than flow rates
calculated from several different landfill operating parameters.
Our conclusion that the approach that FE&C used for calculating the NMOC emission rate at HCRL is
consistent with current EPA guidance is based upon the promulgation date of Subpart VWYW,the
promulgation date of amendments to the rule, and the date that EPA issued its revised Subpart VVWW
implementation guidance. Below is a summary of the relevant dates:
1. March 12, 1996—Initial promulgation date for Subpart WWW.This version of the rule does not
contain any language clarifying Tier 2 and Tier 3 sampling options for landfills that have an
existing GCCS.
2. November 1998—Publication date of initial implementation guidance.The response in Section
IV.B.4 of the guidance document indicates that Tier 2 samples can be collected from the GCCS
header and that, when such sampling is conducted, NMOC emissions may be calculated using
the equations in 40 CFR §60.754(b)or 40 CFR§60.754(a)(1).
2

3. October 17, 2000— Promulgation date of Subpart WWW revisions. One of the changes made to the rul
at this time was the addition of language to 40 CFR §60.754(a)(3)that allows Tier 2 samples to be
collected from an existing GCCS. This new language directs owners and operators that collect Tier 2
samples from the GCCS to calculate NMOC emission rates using the equations in 40 CFR
§60.754(a)(1).
4. May 2002 —Bate that revised implementation guidance was posted on EPA Technology Transfer
Network. The response in Section IV.13.4 of the revised document is identical to the one in the 1998
version.
Although the Subpart WWW revisions promulgated on October 17, 2000, specifically reference the
equations in 40 CFR §60.754(a)(1)when Tier 2 samples are collected from the GCCS, the revised
implementation guidance issued in 2002 also allows the equation in 40 CFR §60.754(b)to be used when
Tier 2 sampling is conducted in the GCCS. Since the calculation approach that FE&C used for the
section of the landfill that is under the influence of the existing GCCS is consistent with the revised
implementation guidance document published after the Subpart WWW revisions were promulgated on
October 17, 2000, it is acceptable to the EPA.
Even in the absence of EPA's May 2002 implementation guidance, we would consider the equation in
40 CFR §60.754(b)a viable alternative,for calculating NMOC emissions when an existing GCCS is in
place. The basis for this position is than when the equation in 40 CFR §60.754(b) is used for the
emission rate calculations,the landfill gas flow rate is measured directly. In contrast, under the equations
in CFR §60.754(a)(1), landfill gas flow rates must be calculated using three different landfill operating
parameters(waste acceptance rates, the age of the waste, and a methane generation rate constant).
Having to account for so many parameters when determining the landfill gas flow rate introduces more
potential for error, and because of this, we would expect the equation in 40 CFR §60.754(b) to yield
results that are at least as"accurate as NMOC emission rate results calculated using the equations in 40
§60.754(a)(1).
In addition to seeking approval for the procedures used to calculate NMOC emission rates at HCRL,
FE&C asked for a change in the deadline for submitting the site's annual NMOC emission rate reports.
Currently, these reports are due in November of each year, and FE&C asked that the due date be moved
to March of each year. The basis for this request is that, by moving the due date for reporting until after
the first of the year, it will be possible to base the NMOC emission rates for the preceding year on the
actual metered flow rate to the flare during the year. Based upon our review,we have determined that
moving the deadline for annual emission reporting to March 31 of each year is acceptable since it will
improve the accuracy of the calculated emission rates.
3

If you have any questions about the guidance provided in this letter,please contact Mr. David McNeal
of my staff at [phone] or at [e-mail].
Sincerely,
Beverly H. Banister
Director
Air,Pesticides and Topics Management Division
Enclosure
cc: Juene Franklin, P.E.
President
Franklin Engineers and Consultants, LLC
4

ATTACHMENT B
RY2019 NSPS ANNUAL NMOC EMISSION RATE CALCULATIONS

Anson County RY2019 NSPS Annual NMOC Emission Rate Calculations
LFG Controlled LFG LandGEM Total NMOC
Extraction
Year Emission Rates Emission Rates Emission Rate
Rate
Rate (Mg/yr) (Mg/yr) (Mg/yr)
2019 696 18.92 7.22 26.14

LANDFILL NAME: ANSON COUNTY WASTE MANAGEMENT FACILITY
REPORTING YEAR: 2019
Contolled NMOC Emission Rate Calculations(under GCCS influence currently in place)
Controlled NMOC Emission Rate Formula:
MNMOC= 1.89E-03 X QLFG X CNMOC
MNMoc= Mass emission rate of NMOC(Mg/yr)
QLFG= LFG Flow rate(m3/min)
CNMOC=* NMOC Concentration,(ppmv as hexane)
QLFG= 696 scfm
QLFG= 20 m3/min
CNMOC=* 508 ppmv as hexane
MNMOC— 18.92 Mg/yr

Summary Report
Landfill Name or Identifier: Anson County Waste Management Facility
Date: Wednesday, March 11,2020
Description/Comments:
About LandGEM:
ra 1
First-Order Decomposition Rate Equation: ��i —�''/
P q �'.,CH4 kL0 10 C;
Where, i=1 j=0.1
QcH4=annual methane generation in the year of the calculation(m 3/year)
i=1-year time increment M;=mass of waste accepted in the i`h year(Mg)
n=(year of the calculation)-(initial year of waste acceptance) t;j=age of the jth section of waste mass M;accepted in the i`h year
j=0.1-year time increment (decimal years,e.g.,3.2 years)
k=methane qeneration rate(year"')
Lo=potential methane generation capacity(m 3/Mg)
LandGEM is based on a first-order decomposition rate equation for quantifying emissions from the decomposition of landfilled waste in municipal
solid waste(MSW)landfills.The software provides a relatively simple approach to estimating landfill gas emissions.Model defaults are based on
empirical data from U.S.landfills.Field test data can also be used in place of model defaults when available.Further guidance on EPA test
methods,Clean Air Act(CAA)regulations,and other guidance regarding landfill gas emissions and control technology requirements can be found
at hfp://www.epa.gov/ttnatw0l/landfill/landflpg.htmi.
LandGEM is considered a screening tool—the better the input data,the better the estimates.Often,there are limitations with the available data
regarding waste quantity and composition,variation in design and operating practices over time,and changes occurring over time that impact the
emissions potential.Changes to landfill operation,such as operating under wet conditions through leachate recirculation or other liquid additions,
will result in generating more gas at a faster rate.Defaults for estimating emissions for this type of operation are being developed to include in
LandGEM along with defaults for convential landfills(no leachate or liquid additions)for developing emission inventories and determining CAA
applicability.Refer to the Web site identified above for future updates.
Input Review
The 80-year waste acceptance limit of the model has been
LANDFILL CHARACTERISTICS exceeded before the Waste Design Capacity was reached.The
Landfill Open Year 2001 model will assume the 80th year of waste acceptance as the
Landfill Closure Year(with 80-year limit) 2080 final year to estimate emissions.See Section 2.6 of the User's
Actual Closure Year(without limit) 2183 Manual.
Have Model Calculate Closure Year? Yes
Waste Design Capacity 11,495,514 short tons
MODEL PARAMETERS
Methane Generation Rate,k 0.050 year-'
Potential Methane Generation Capacity,Lo 170 m 3/Mg
NMOC Concentration 367 ppmv as hexane
Methane Content 50 %by volume
GASES/POLLUTANTS SELECTED
Gas/Pollutant#1: Total landfill gas
Gas/Pollutant#2: Methane
Gas/Pollutant#3: Carbon dioxide
Gas/Pollutant#4: NMOC

Summary Report
Landfill Name or Identifier: Anson County Waste Management Facility
Date: Wednesday, March 11, 2020
Waste Accepted Waste-In-Place NMOC
Year (short tons/yr) (short tons) (Mg/yr)
20011 18,926 0 0.00
2002 18,926 18,926 0.38
2003 18,926 37,853 0.73
2004 18,926 56,779 1.07
2005 18,926 75,706 1.40
20061 9,054 94,632 1.71
20071 20,663 103,686 1.80
20081 12,418 124,349 2.13
20091 15,680 136,767 2.27
2010 21,583 152,447 2.47
2011 23,804 174,030 2.78
2012 19,517 197,834 3.12
2013 29,629 217,352 3.35
20141 39,831 246,981 3.78
2015 36,058 286,812 4.39
2016 42,753 322,870 4.89
2017 57,116 365,622 5.50
2018 58,520 422,738 6.37
2019 66,950 481,259 7.22
2020 66,950 548,209 8.20
20211 66,950 615,158 9.13
2022 66,950 682,108 10.02
2023 66,950 749,058 10.86
2024 66,950 816,008 11.66
2025 66,950 882,958 12.42
20261 66,950 949,908 13.15
2027 66,950 1,016,857 13.84
2028 66,950 1,083,807 14.49
2029 66,950 1,150,757 15.12
2030 66,950 1,217,707 15.71
20311 66,950 1,284,657 16.28
20321 66,950 1,351,607 16.81
2033 66,950 1,418,556 17.32
2034 66,950 1,485,506 17.81
2035 66,950 1,552,456 18.27
2036 66,950 1,619,406 18.71
20371 66,950 1,686,356 19.13
2038 66,950 1,753,306 19.53
2039 66,950 1,820,256 19.91
2040 66,950 1,887,205 20.27

ATTACHMENT C
RESPONSIBLE OFFICIAL STATEMENT OF CERTIFICATION

Statement of Certification by Responsible Official
In accordance with the requirements of Title V Permit Condition 3.Q, we have included a certification by the Responsible
Official.
I, the undersigned, certify that, based on information and belief formed after reasonable inquiry, the statements and
information in the document are true,accurate,and complete.
Responsible Official
ignature
Responsible Official Tyler Fitzgerald
Print
Responsible Official Title 5 t n.�44 ti�AV\46 6(-'
Date 3 �1 l aoav