AQ_F_0800102_20210406_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: 04/06/2021
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
Matt Einsmann,P.E. Shane Walker Matt Einsmann,P.E. MACT Part 63: Subpart AAAANSPS: Subpart WWW
Environmental Manager Area President Environmental Manager
[phone] [phone] [phone]
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 04/06/2021
inspection. Inspector's Name Kurt Tidd
Operating Status Operating
Inspector's Signature: Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Compliance
Date of Si nature:04/08/2021
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2017 6.62 3.22 33.65 13.44 123.69 6.62 6088.25
*Highest HAP Emitted in ounds)
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
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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.
FACILITY SAFETY:
A reflective safety vest is always required at the facility. A hardhat is required when in the landfill area.
A face mask is required during the Covid 19 pandemic.
PERMITTED SOURCES:
Emission Source ID Emission Source Control Device ID Control Device Description
No. Description No.
ES-01 Municipal solid waste CD-GCCS I 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)
Insi nificant 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
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INSPECTION OBSERVATIONS/RESULTS:
On 04/05/2021 I 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 in the conference room where social distancing could
be maintained.
After the records review, we toured the landfill and made the following observations. At the time of the
inspection, both flares were in operation, no Visible Emissions were noted from the flares. They were
receiving approximately 1,700 scfm of Landfill gas from each flare. Both flares each have capacity of
4,000 scfm. The flares have a propane ignition system.
I observed the area were the waste was being placed, I did not see any fugitive emissions from this 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.
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.
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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, 2020 thru December 31, 2020 and collection
data through March 31, 2021 have indicated that methane exceedances have occurred during that period.
Corrective action and follow-up monitoring within 10 days of the exceedance measured methane
concentrations below the 500-ppm standard. Compliance is indicated.
Additional Recordkeeping 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
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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 July 1, 2020
thru December 30, 2020 was received on January 28, 2021. 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.
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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 July
1, 2020 thru December 30, 2020 time-period was received on January 28, 2021. 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 2020 was 148.6 tons of CO,
below the 250-ton limit.
The last semi-annual report covering the July 1, 2020 thru December 30, 2020 time-period was received
on January 28, 2021. 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 (MOD'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. The landfill will be subject to Subpart
XXX effective the date of the rule and the permit renewal.
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