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HomeMy WebLinkAboutAQ_F_0800102_20220721_CMPL_InspRpt NORTH CAROLINA DIVISION OF Washington Regional Office AIR QUALITY East Carolina Regional Solid Waste Landfill NC Facility ID 0800102 Inspection Report County/FIPS:Bertie/015 Date: 07/21/2022 Facility Data Permit Data East Carolina Regional Solid Waste Landfill Permit 08849/T08 1922 Republican Road Issued 10/27/2016 Aulander,NC 27805 Expires 9/30/2021 Lat: 36d 6.9563m Long: 77d 4.1832m Class/Status Title V SIC: 4953/Refuse Systems Permit Status Active NAILS: 562212/Solid Waste Landfill Current Permit Application(s)TV-Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Wes Mankusser Shane Walker Matt Einsmann,P.E. MACT Part 63: Subpart AAAANSPS: Subpart WWW Operations Manager Area President Environmental Manager (919)354-3227 (980)430-8511 (919)354-3227 Compliance Data Comments: The facility appeared to be operating in compliance with all applicable Federal and State rules,regulations and permit conditions at the time of the Inspection Date 07/19/2022 inspection. Inspector's Name Kurt Tidd Operating Status Operating Compliance Status Compliance-inspection Inspector's Signature: Action Code FCE Inspection Result Compliance Date of Signature: 07/25/2022 Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2020 6.31 6.19 32.69 13.04 119.37 6.31 4216.96 2019 6.36 6.27 32.90 11.45 120.27 6.36 5918.32 2018 6.64 3.21 33.71 13.92 123.92 6.64 6100.05 *Highest HAP Emitted(in pounds Five Year Violation History:None Performed Stack Tests since last FCE:None FACILITY LOCATION: This facility is located on 1922 Republican Road. From WaRO take Hwy 17 to Williamston and continue on Hwy 13/17 towards Windsor. Take a left onto Rte 308 towards Drew at the stoplight just past the FORD dealership (on right will be a convenience store). Republican Road(SSR 1225) comes up on the right within 2 miles. Follow Republican Road for approximately 9 miles (will have to cross School Road) and the facility will be on the right. Take note that Republican Road will veer to the left approximately 1.1 miles before the facility. PROCESS DESCRIPTION: East Carolina Regional Solid Waste Landfill (ECRSWL) is a municipal solid waste landfill owned by Republic Services of North Carolina that receives municipal solid waste, construction/demolition debris, and non-hazardous special wastes. The landfill is lined with a geomembrane material. Landfill gas (LFG) is collected and flared. FACILITY SUMMARY: A second flare (CD-Flare2)was installed and became operational on August 23, 2012. After the issue of T06, an appeal was filed and a Special Order of Consent became effective on August 6, 2012. In the Review for Permit T07, CISWI was determined to be non-applicable. Revised Permit 08849T07 was issued with an effective date of August 7, 2013 and expired February 28, 2017. Permit 08849T08 was issued on October 27, 2016 and expires on September 20, 2021. A renewal has been submitted to the RCO for processing. FACILITY SAFETY: A reflective safety vest is always required at the facility. A hardhat is required when in the landfill area. PERMITTED SOURCES: Emission Source ID Emission Source Control Device ID Control Device Description No. Description No. ES-01 Municipal solid waste CD-GCCS 1 One landfill gas collection (NSPS,MACT) landfill and control system CD-Flarel One landfill gas-fired open flare (3000 scfin maximum flow rate) CD-Flare2 One landfill gas-fired open flare (3000 scfin maximum flow rate Insignificant Sources: Emission Source ID No. Emission Source Description IES-04 Diesel engines for miscellaneous landfill support IES-05 Welding operations IES-06 Diesel storage tank IES-07 Two leachate storage tanks INSPECTION OBSERVATIONS/RESULTS: On 07/19/20221 conducted a Full Compliance Evaluation(FCE) of ECRSWL which was in operation at the time of the inspection. I met with Matt Einsmann, Environmental Manager for Republic Services who had laid out all of the records for my review. I reviewed the following records for 2021 through May of 2022: • Monthly well logs • Monthly flare logs • SSM and downtime records for the flares • Well parameter reports • Monthly GCCS forms • Daily logs • VE forms • Monthly coverage inspections • Surface methane reports Some of the SSM forms did not match up with the downtime reports, I discussed this with Mr. Einsmann, who was going to get them corrected and resubmitted. The landfill was in full operation at the time of the inspection. Both flares were in operation, they were receiving approximately 2,800 scfm, combined of Landfill gas to the flares. Both flares have combined capacity of 4,000 scfm. The flares have a propane ignition system. I did not see any fugitive emissions from the landfill area. There were some fugitives from trucks and equipment driving on the access roads of the landfill. ECRSWL does have a watering truck to control this if it gets too bad. No fugitives were observed leaving the property. The facility receives approximately 2,000 tons per day of waste. I was also able to observe the area in which some new wells were being placed. Currently there are 120 wells installed at the facility, 18 cleanouts, three manholes, five PV Wells, and 18 gas well-water pumps. The collection system(under a negative pressure from two blowers at the flare) allows gas to migrate to the flares where it is combusted. Underneath the fill, there is a 60-mil plastic liner that allows leachate to drain to a collection point where it is pumped to leachate storage tanks near the flare skid. The leachate is taken to Rocky Mount for disposal in their wastewater treatment system. They do not recirculate the leachate. They are currently constructing a new cell and closing out the existing cell. The facility now uses soil and tarps as a daily cover material instead of"POSISHELL." Currently, the facility is permitted for approximately 23 million cubic yards (MCY) of air space (mound height). The facility is currently using cell 14. And they are planning on expanding both up and out as the waste comes in. Mr. Einsmann said that there are looking into a gas treatment system that would change the LFG to a pipeline quality gas. East Carolina Landfill submitted a Title V renewal application to the RCO on December 21, 2020. REGULATORY REVIEW: 2D .0524,NSPS, Subpart WWW—The landfill has a design capacity of 5.9 million Mg which exceeds the threshold of 2.5 million Mg. Therefore, the landfill must use a collection and control system. To comply with this Rule, ECRSWL utilizes two flares that meet the requirements of 40 CFR 60.18 (requirements pertaining to gas flow). During flare operation, ECRSWL is required to operate a heat sensing device to indicate the continuous presence of a flame. They must also operate a device that records flow to or bypass of the flare. ECRSWL must maintain a gas flow rate measuring device that records the flow to the control device at least every 15 minutes or secure the bypass line valve in the closed position. Initial testing is required indicating that the flare meets the requirements of 40 CFR 60.18. The flare operational records must be maintained for 5 years. Operation of the flares is monitored and controlled at control panels located on the blower skid, which manage start-up and shut-down activities, as well as record the flow rate and temperature of LFG for each flare. If either flare shuts down, the control panel automatically closes the appropriate shut-off valve, closing off all LFG flow to that flare stack, thus preventing free venting of non-combusted LFG. At each landfill wellhead, Carlson Environmental Services (CES) measures and monitors the gauge pressure in the gas collection header, and landfill gas oxygen concentration and temperature monthly for ECRSWL. CES conducts the monitoring twice each month. If either a positive pressure, temperature greater than 55C (131F), and with either percent nitrogen, greater than 20%, or percent oxygen, greater than 5% exists, then a corrective action must be initiated within 5 days and rechecked within 15 calendar days. If the exceedance cannot be corrected within 15 days of the first measurement, the gas collection system shall be expanded to correct the exceedance within 210 days of the initial exceedance. ECRSWL must keep records for at least five years of all collection and control system exceedances of the operational standards, the reading in the subsequent month and whether the second reading is an exceedance, as well as the location of each exceedance. A higher operating temperature, nitrogen, or oxygen value at a well (HOV) can be allowed provided data is if shows that a fire is not occurring or no significant inhibition of anaerobic decomposition via methanogenesis. ECRSWL keeps logbooks that contains spreadsheets of the monthly readings of the gauge pressure, temperature and percent oxygen. While instances of an exceedances were noted, corrective actions were taken in a timely manner. The exceedances are typically corrected by adjusting the wellhead vacuum. The facility must monitor surface concentrations of methane along the entire perimeter of the collection area and along a pattern that traverses the landfill at 30-meter intervals (or site-specific established spacing) for each collection area on a quarterly basis. The methane concentration must be less than 500 parts per million above background concentrations at any surface of the landfill. If a location has an exceedance of the 500-ppm standard, then a second reading must be taken within 10 days; otherwise, a reading must be taken one month from the initial exceedance. If an exceedance occurs again, another reading must be taken within 10 days. For any three exceedances that occur at any location within a quarterly period, a new well or collection device must be installed within 120 days of the initial exceedance. I reviewed the records for quarterly surface monitoring of methane. The routes are explained in the design plan. The semi-annual reports covering January 1, 2021, thru December 30, 2021, and collection data through March 31, 2021 have indicated that methane exceedances have occurred during this period. Corrective action and follow-up monitoring within 10 days of the exceedance measured methane concentrations below the 500-ppm standard. The 1st semi-annual report has not come out as of the date of this report. The state does not have delegation of the new Subpart XXX until it is approved in the SIP or the in this case until the permit is renewed. Compliance is indicated. Additional Recordkeepin2 Requirements ECRSWL must keep record records of the maximum design capacity, the current amount of solid waste in-place, and the year-by-year waste acceptance rate for at least five years. The records of control device vendor specifications shall be maintained until removal. The following records must be maintained for the life of the control equipment: • Data measured during the initial performance test or compliance determination, continuous records of operating parameters, readily accessible plot map showing each existing and planned collector in the system and providing a unique identification location label for each collector, installation date and location of all newly installed collectors, documentation for the date of deposition, amount, and location of asbestos-containing or non-degradable waste excluded from collection as well as any nonproductive areas excluded from production. • Records of all collection and control system exceedances of the operational standards shall be maintained for a minimum of five years. Compliance is indicated as the facility appears to be keeping these records. Reporting Requirements The submittal of annual reports noting exceedances of wellhead parameters, periods when the LFG stream is diverted from the flare, periods when the flare is not operating, periods when the collection system was not operating in excess of 5 days, the location and concentration of each methane concentration exceedance, the date of installation of each well or collection system expansion added, and a summary of all DAQ approved decommissioned well closures and nonproductive areas is required. The reports must be submitted 30 days after each calendar half for the preceding six-month period. All instances of deviations from the requirements must be clearly identified. These reports are being submitted semi-annually. The last semi-annual report covering the 07/01/2021 thru 12/30/2021 was received on 01/27/2022. The Annual Compliance Certification was received on 02/28/2022. All reports have been reviewed and approved. WaRO's review of these reports indicates compliance. 2D .0516—Sulfur Dioxide Emissions from Combustion Sources Sulfur dioxide emissions are limited to 2.3 lbs per million Btu. Landfill gas combustion produces negligible sulfur dioxide emissions. Compliance is indicated. 2D .0521 —Control of Visible Emissions Visible emissions are limited to 20 percent opacity. No VE was observed during the inspection and there no DAQ records of complaints regarding visible emissions. Compliance is indicated. 2D .1806—Control and Prohibition of Odorous Emissions ECRSWL is required to take suitable measures to control odorous emissions. No odor was detected during inspection outside the property line of the facility and there are no DAQ records of complaints regarding odorous emissions. Compliance is indicated. 2D .1111, 40 CFR Part 63, Subpart AAAA: National Emissions Standards for Hazardous Air Pollutants,Municipal Solid Waste Landfills The regulation references compliance with 40 CFR Part 60, Subpart WWW and additionally requires the implementation of a startup, shutdown and malfunction plan(SSM)that must be maintained on site. The SSM is a corporate plan used at all Republic facilities. A 40 CFR 63.10(d) (5) SSM report noting actions taken to minimize emissions must be submitted semi- annually and is due by 30 days after each calendar half. Also, immediate reports of SSMs are required within 2 days and a letter is required within 7 days if any actions taken are not consistent with the SSM plan. The records review indicates that several startup/shutdown events did occur, most of which were due to power failures,but compliance is noted via the checklist. The last semi-annual report covering the 07/01/2021 thru 12/30/2021 time-period was received on 01/27/2022. WaRO's review of these reports indicates compliance. 2Q .0317—Avoidance Conditions (21) .0530 Prevention of Significant Deterioration—Carbon Monoxide) Open flares (CD-Flarel and CD-Flare2) are limited to 250 tons of Carbon Monoxide discharged into the atmosphere and combustion less than 2,628,000,000 ft3 of landfill gas per consecutive 12-month period. The Permittee shall keep monthly records of the amount of landfill gas burned in open flares, as well as monthly carbon monoxide emissions. A report containing the monthly carbon monoxide emissions for the previous 12 months over a 17-month period and the monthly landfill gas flow rate quantities for each flare in the previous 17 months must be submitted by 30 days after each calendar half for the preceding six-month period. The 12-month rolling total in reported in December 2021 was 150.7 tons of CO, below the 250-ton limit. The last semi-annual report covering the 07/01/2021 thru 12/30/2021 time-period was received on 01/27/2022. WaRO's review of these reports indicates compliance. 2D .0535—Excess Emissions A search of DAQ records indicates no reports regarding excess emissions have been received since the last inspection. Compliance is indicated. General Conditions and Limitations. The facility appeared to be operating in compliance with all General Conditions and Limitations at the time of the inspection. FIVE YEAR COMPLIANCE HISTORY: No Notices of Violation(NOV's) or Notices of Deficiencies (NOD's) have been issued to the facility in the last five years. CONCLUSIONS, COMMENTS AND RECOMMENDATIONS: The facility appeared to be operating in compliance with all applicable Federal and State Air Quality rules, regulations and permit conditions at the time of inspection.