AQ_F_0400052_20201123_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Anson County Waste Management Facility
NC Facility ID 0400052
Inspection Report County/FIPS:Anson/007
Date: 12/10/2020
Facility Data Permit Data
Anson County Waste Management Facility Permit 09835/T04
375 Dozer Drive Issued 2/26/2019
Polkton,NC 28135 Expires 1/31/2024
Lat: 35d 0.2610m Long: 80d 9.7720m Class/Status Title V
SIC: 4953/Refuse Systems Permit Status Active
NAICS: 562212/Solid Waste Landfill Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
MACT Part
Tyler Fitzgerald Tyler Fitzgerald Lana Brown rt Subpart 6C
NSPS: Subpart XXX
District Manager District Manager Eastern Region Env.
[phone] [phone] Manager
[phone]
Compliance Data
Comments:
Inspection Date 11/23/2020
Inspector's Name Jeffrey D.Cole
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
/ Action Code FCE
Date of Signature: /���-3 On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 1.34 0.9100 5.45 3.81 29.65 1.34 2274.97
2018 0.8800 0.6000 3.56 3.32 19.35 0.8800 1974.04
2017 1.07 0.7300 4.36 2.83 23.70 1.07 1664.09
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

I. Location/Directions: Anson County Waste Management Facility is located at 375 Dozer Drive,
near Polkton,NC,Anson County. Directions: From FRO,Head south on Green St.toward
Maiden Ln., at traffic circle take the second exit to Gillespie St. for 0.2 miles. Turn right on West
Russell St. for 0.5 miles,turn left onto Robeson St. for 2.4 miles. Turn right onto Raeford Road,
Hwy 401, south to Wagram,—32 miles. Just past Wagram,turn right onto Old Wire Road(SR
144)to Laurel Hill. Turn right(west) on Highway 74 and go approx. 41 miles. Turn right
between NC DMV office building and bridge over Brown Creek. Go approx. 0.4 mile and the
landfill office is on the right.
IL Safety: Helmet, safety boots and safety vest are required when near the working face of the
landfill. The principal hazards are from truck traffic and falls/sprains from walking on the uneven
ground.
III. Description: The Anson County Waste Management Facility(ACWMF) is a municipal solid
waste(MSW)landfill located near the town of Polk-ton,Anson County,North Carolina. The
landfill began accepting waste in 2001. The facility installed a voluntary gas collection and
control system to control odor,to minimize landfill gas migration,to allow the facility to build
carbon credits,and to pursue gas-to-energy projects. The initial Air Quality permit was a state
issued Synthetic Minor Permit for a waste gas flare because at that time the design capacity was
less than Title V thresholds. On September 24,2013,the facility was issued the initial Title V
permit.
The design capacity of this facility is currently greater than the NSPS, Subpart W W W,
applicability threshold of 2.5 million cubic meters by volume and 2.5 million mega grams by
mass. The facility performed Tier 2 testing on December 15,2011 and the results indicated that
the NMOC emissions were below 50 mega grams per year(threshold to require a mandatory gas
collection and control system). The Tier II results indicated an additional 5 years,with no GCCS
requirement by Air Regulations NSPS W W W thru 2016. This facility performed its most recent
Tier 11 test in December 2018 and into January 2019 and submitted a test report on February 28,
2019. The data summary of that report that was approved by DAQ indicates the facility
continues to test out,less than 50 Mg/yr NMOC until 2022(28.89 Mg/yr in 2022)
On March 26,2018,NCDEQ Solid Waste Division issued to ACWMF a Permit-To-Construct for
Phase 3 and 4. On May 9,2018, construction of Phase 3 began and triggered NSPS XXX. The
Initial Design Capacity Report to meet the requirements of NSPS XXX,40 CFR 60.767(a)(1)(i)
and 40 CFR 60.676(b)(1)(i)(A)was submitted to DAQ on August 3,2018 to meet an
August 7, 2018 deadline. That report contained a NMOC Tier 1 calculation indicating the
NMOC 867.5 Mg/yr. This facility elected to perform a Tier 2 Test to determine actual NMOC
emissions. As noted above,the facility performed another Tier II test in December 2018 and into
January 2019. The data summary of that report that was approved by DAQ indicates the facility
continues to test out, less than 34 Mg/yr.NMOC until 2022. The facility has options to perform
further testing as contained in NSPS XXX. However, should the facility not be able to test out of
the requirement of a GCCS as required by NSPS XXX,the facility has 30 months from the Initial
Design Capacity Report submitted on August 3,2018 to fully comply with NSPS XXX. Also,
ACWMF submitted a permit application to include NSPS XXX and to renew their permit
15 November 2017. That permit(T04),was issued on 26 February 2019.

IV. Current throughputs: The landfill is currently accepting MSW at an average rate of 2,800 TPD.
The average LF Gas Flow rate was not recorded during this inspection however the flare was
observed to be operating.
V. Current Permitted Emission Sources
. ' Cnutr of Device Control System
Emission Source ID Emission Sourco"DescnpYigii �ED, 1)escri Lion
GCCS-1 * Gas collection and
control system
One municipal solid waste landfill CD-1
ES-1 Candle stick type flare
NSPS Subpart XXX Waste Acceptance Rate of an Collecting LFG and (2500 scfm,75 million
annual average of 2,800 TPD Btu per hour heat input
flaring on inspection @ 500 Btu/ft'heat rate
date. of landfill gas)
*Voluntary gas collection and control system(not yet required by 40 CFR 60,XXX);Testing in December 2018 and into
January 2019 indicated the facility continues to test out,less than 34 Mg/yr NMOC until 2022,and thus,no further requirements
under NSPS XXX are required at this time. This facility will become subject to NESHAP AAAA when and if the facility came
no longer test out of 50 Mega grams of NMOC.
VI. Inspection Conference: On November 23, 2020,I, Jeffrey Cole of NC DAQ FRO met with
Tyler Fitzgerald,District Manager, and Mr.Dustin Towne, facility operator for an Air Quality
TV permit inspection. I met with facility personnel outside the facility's office to comply with
COVID-19 pandemic restrictions. I presented the Facfmder to Mr. Fitzgerald and he noted that
no changes were needed. Mr. Fitzgerald noted that no dust complaints had been received by the
landfill. Mr. Fitzgerald also noted there had been no odor complaints received by the landfill
since the last compliance inspection other than the complaint received by FRO in July 2020.
Presently the Air Quality permit is relatively simple until this facility grows to the point where
they can no longer test out of the requirements of needing a Design Plan for an engineered GCCS
as required by NSPS XXX. The following items were discussed:
• We discussed the waste acceptance rate.Mr. Fitzgerald indicated the rate varied
between 2,700 and 3,000 TPD and remarked that the COVID-19 pandemic had not
effected the landfills waste acceptance rate. On the date of the inspection the landfill
was accepting MSW at an average rate of 2,800 TPD.
• The present GCCS installed voluntarily before required by NSPS XXX.
• Mr. Fitzgerald stated that the facility will be installing 5 new gas wells in
December 2020.
Inspection Summary: I proceeded to follow Mr. Fitzgerald and Mr. Town's truck, in my State
vehicle, out to the working face of the landfill. On the way to the working face I noted that the
landfills flare was operating. Mr. Fitzgerald explained that the landfill is currently adding waste
to their Phase 3 area. I returned to the office parking lot and conducted by post inspection
conference.

VH. Stipulation Review for Section 2- Specific Limitations and Conditions:
1. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from Flare
(ID No. CD-1) shall not exceed 2.3 pounds per million Btu heat input.
APPEARS IN COMPLIANCE: The AP-42 emission factor for flare combustion of MSW
landfill gas is equivalent to natural gas at 0.006 lbs./mmBtu which is much less than required
S02 limit.
2. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from Flare(ID No. CD-1),
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six-minute period,except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period.
APPEARS IN COMPLIANCE: On my drive out to the working face of the landfill I
stopped my vehicle and observed that the flare was operating at 0% opacity.
3. STANDARDS OF PERFORMANCE FOR MUNICIPAL SOLID WASTE LANDFILLS
THAT COMMENCED CONSTRUCTION,RECONSTRUCTION,OR
MODIFICATION AFTER JULY 17,2014 as required by 15A NCAC 2D .0524,40 CFR
Part 60, Subpart XXX. The Permittee shall comply with all applicable provisions,
including the notification,testing,recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 02D .0524 "New Source
Performance Standards(NSPS)"as promulgated in 40 CFR Part 60 Subpart XXX,including
Subpart A "General Provisions." Compliance with the NSPS Subpart XXX regulations
referenced in Section 2.1.A.3. of this permit will be required when applicable. [15A NCAC
02D .0524]. The facility is required to submit a semiannual summary report of the
monitoring and recordkeeping activities and indicate if there are any deviation.
APPEARS IN COMPLIANCE: This facility is subject to NSPS XXX,however in
December 2018 and in January 2019,the facility performed a Tier 2 Test as outlined in 40
CFR 60.764 that deferred the requirement of a GCCS. The calculated NMOC emissions
report indicated that the facility would not be required to install an engineered GCCS before
2022. The facility submitted a 5-year report demonstrating compliance. Therefore, an annual
report is not required. The calculated NMOC for the fifth year in 2022 is 28.89 Mg/yr.
When the landfill emissions exceed 50 Mg/yr of NMOC,the facility will no longer have a
volunteer GCCS and will be required to meet the additional requirement of NSPS Standard
for MSW Landfills, like monitoring the gas well, surface scans, and gas well expansion every
five year at minimum. Presently the facility has a voluntarily GCCS consisting of 35 gas
wells and 4 leachate cleanout headers routed to the flare. The most recent NSPS XXX
semiannual summary report was received on 7/27/20 and appeared to show compliance. The
NSPS XXX annual report is not required until the landfill is required to operate a GCCS to
meet the full requirements of NSPS XXX.

4. CONTROL OF ODOROUS EMISSIONS—As require by 15A NCAC 2D .1806: 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
APPEARS IN COMPLIANCE: CONCERN NOTED: I did not observe any objectionable
odors beyond the property boundary. There was a complaint that was investigated and the
results of that investigation are as follows. On 17 July 2020 a complaint was received about
landfill odors coming from the landfill. The anonymous complainant stated that they have
been smelling odors from the landfill for the last 9 to 10 months(starting in October 2019).
They also noted that it is the worse in the evening when the air is heavy. DAQ FRO
investigated this complaint on 7 August 2020, after conducting a compliance inspection of
the Anson County Waste Management Facility, and detected no odor around the
complainant's residence. DAQ FRO closed the odor complaint but continued to investigate
any further odor complaints that occur.
After this compliance inspection, specifically on 7 December 2020,the FRO received an odor
log from the same anonymous complainant from July 2020, noting additional odor
observations from 30 October through 30 November 2020. Currently,I am reviewing wind
direction data from the dates and times listed on the odor log and I am planning on calling the
landfill to ask about operations and events that may have contributed on these dates where the
observations were made.
5. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT -Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration,the
following permit limits shall not be exceeded:
Projected emission rates through landfill closure in the year 2044
....,a ., --_, r—
° issl tt
.P.
Benzene 108.62lb/yr
Landfill(ES-1) Hydrogen chloride F -----
Fugitive emissions Hydrogen sulfide F 3.16 lb/day
Vinyl chloride 96.56 lb/yr
„ ..
� 7 t v91
Benzene 5.261b/yr
0.591b/hr
Candlestick flare(CD-1) Hydrogen chloride
Hydrogen sulfide 0.15 lb/day
Vinyl chloride F 4.66 lb/yr
APPEARS IN COMPLUNCE: Modeling was based on LANDGEM-generated flow rates
at peak generation rates without control and indicated less than 28%AAL for any TAP. The
landfills operations have not changed since that modeling was completed.
Per the permit review and Toxic evaluation in 2007 and revised in 2014 and again in 2019,
HCL, Benzene,Hydrogen sulfide,and Vinyl chloride emission were modeled and were well
below the AAL based on a LFG flow rate of 2000 cfm burned. Therefore,under normal
operation, around 450 to 550 scfm,this MSW landfill will not exceed Toxic limits. While at

the time of the inspection the LFG flow rate is around 760 scfm do to less rain events in
recent months,this flow rate fluctuates seasonally, and thus,this MSW landfill is not likely to
exceed Toxic limits. This facility will become subject to NESHAP AAAA when the facility
can no longer test out of 50 Mg/yr of NMOC. Based on present regulatory requirement this
facility will then no longer be subject to NC State Toxics because it will be regulated by a
federal NESHAP rule.
6. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed toxic
air pollutants (TAPS),the Permittee has made a demonstration that facility-wide actual
emissions do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q
.0711.The facility shall be operated and maintained in such a manner that emissions of any
listed TAPS from the facility, including fugitive emissions,will not exceed TPERs listed in
15A NCAC 2Q .0711. The Permittee shall maintain records of operational information
demonstrating that the TAP emissions do not exceed the TPERs as listed below:
APPEARS IN COMPLIANCE: Compliance was determined during the most recent permit
review based on operating the source as described in the permit conditions. No changes have
been made to operations since that determination.
7. REPORTING REQUIREMENTS: GENERAL CONDITION P-Compliance certification
requires annual submittal of compliance certification report, due by March 1 of each year.
APPEARS IN COMPLIANCE: The most recent ACC was received on January 29,2020
and has been reviewed and approved by DAQ FRO.
8. REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND PERMIT
DEVIATIONS: GENERAL CONDITIONS LA and I.B [15A NCAC 2D .0535(f) and 2Q
.0508(f)(2)]. This stipulation requires the facility to report excess emission above any
emission standard or limit.
APPEARS IN COMPLIANCE: Mr. Fitzgerald stated that no excess emission events or
permit deviations have occurred, and therefore no notification has been required.
9. PERMIT RENEWAL: GENERAL CONDITION K[15A NCAC 2Q .0508(e)and 2Q
.0513(b)] This 15A NCAC 2Q .0500 permit is issued for a fixed term not to exceed five years
and shall expire at the end of its term. Permit expiration terminates the facility's right to
operate unless a complete 15A NCAC 2Q .0500 renewal application is submitted at least nine
months before the date of permit expiration.
10. General Condition X"Annual Emission Inventory Requirements": The most
recent AQEI was received on 6/16/2020 for the 2019 data and was deemed complete.
The next APEI is due on 6/30/21 for the 2020 emissions data.
11. General Condition MM—"Fugitive Dust Control Requirement": Mr. Fitzgerald
stated that the facility has not received any dust complaints. No fugitive dust
complaint has been recorded by DAQ and no fugitive dust was observed leaving the
property line on 11/23/2020.

APPEARS IN COMPLIANCE: The Air Permit expiration date for the present permit,Air
Permit No. 9835T04, is January 31, 2024. The facility should submit a permit renewal on,or
before, July 31,2023.
12. 112R STATUS: Anson County Waste Landfill does not store any listed chemicals above the
threshold quantities, and is not required to maintain a written Risk Management Plan(RMP).
13. Non-Compliance History Since 2010: None
VIH. Comments and Compliance Statement: Anson County Waste Management facility
appears in compliance based on this inspection and the data summary contained in the NSPS
VOW W Tier 2 performed in December 2018 and into January 2019. However,FRO is currently
reviewing a new odor complaint received in an odor log from an anonymous complainant who
lives near the landfill.
PINK SHEET ADDITIONS: None.
/jdc