AQ_F_0800102_20190426_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: 05/20/2019
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)None
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: Based on visual observation and records review,the facility appeared
to operate in compliance with all applicable Air Quality regulations and permit Inspection Date 04/26/2019
conditions at the time of inspection. Inspector's Name Robert Bright and Robert Fisher
Operating Status Operating
Compliance Code Compliance-inspection
Inspector's Signature: Action Code FCE
On-Site Inspection Result Compliance
Date of Signature: May 20,2019
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 6.62 3.22 33.65 13.44 123.69 6.62 6088.25
2016 7.24 3.47 36.15 12.98 135.08 7.24 6656.00
2015 5.46 2.73 28.92 12.38 121.64 5.46 5015.40
*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 past the FORD dealership(on right will be a
convenience store). Republican Road(SSR 1225)comes upon 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.
https://ncconnect.sharcpoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00102/20190426.a l 6.docx 1

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 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.
On April 26,2019,I conducted a full compliance evaluation with the assistance of Robert Fisher,WaRO RAQS,and Matt
Einsmann,Environmental Manager.
PERMITTED SOURCES:
Emission Source ID No. Emission Source Description Control Device ID No. Control Device Description
ES-01 Municipal solid waste landfill CD-GCCS 1 One landfill gas collection and
(NSPS,MACT) 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 niticant 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:
ECRSWL was in operation at the time of the inspection. No off-site dust,odor,or source specific visible emissions were
observed.ECRSWL has approximately 100 wells at the site, 18 cleanouts,three man-holes,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
flare where it is combusted. Underneath the fill,there is a 60-mil plastic liner that allows liquids to drain to a collection point
where it is pumped to leachate storage tanks near the flare skid. The liquid is then currently hauled offsite for disposal.
Leachate collection has improved from 7,000,000 gallons in CY2015 to 13,000,000 gallons in CY2018.
At the end of each day,the area to which fill has been added is covered with a layer of material called"POSISHELL." This
material is similar to cement without the aggregate and is used to ensure wind will not disperse the material which has just
been deposited. Currently,the facility is permitted for approximately 23 million cubic yards(MCY)of air space(mound
height). The facility is currently using cell 13. Cell 14,which has been permitted with Solid Waste,is currently under
https://ncconnect.sharcpoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00102/20190426.aI 6.docx 2

construction,and is projected to add 1.24 MCY of air space. There are current plans for use of the LFG,which will continue
to be burned off in the flares.
We went to wellhead 309A to watch a demonstration of the wellhead monitor used for CO,CH4,oxygen and temperature.
During a tour of the facility during the inspection,both flares were operating. No visible emissions were observed. The
following operational parameters were observed during the inspection:
Temperature F Gas Flow Rate scfm Blower Vacuum H2O"
CD-Flare 1 1,347 1,808 -44.024"
CD-Flare2 650 1,489
The flares have an in-line flash arrester to keep fire from traveling back up the pipe. Propane is used to start the flare after it
has been shutdown(until the LFG starts to flow through the isolation valve).
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 open 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 uncombusted 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.
Since the previous inspection,the several variance requests have been reviewed and granted by WaRO. Attached to the
report is a list of the current HOVs and those proposed for certain wellheads. HOVs were discussed and Republic gave a
presentation on"warm"landfills and the operational challenges they present The presentation is stored
at:https://ncconnect.sharepoint.com/site s/DAQ-
W aRO/Facilities/B ertie08/00102/Michael%20Beaudoin%20EREF%20presentation%20.pdf.
WaRO was asked their interpretation of 40 CFR 60.753(c),regarding states the following: Operate each interior wellhead
in the collection system with a landfill gas temperature less than 55°C and with either a nitrogen level less than 20 percent
or an oxygen level less than 5 percent. The owner or operator may establish a higher operating temperature, nitrogen, or
oxygen value at a well.A higher operating value demonstration shall show supporting data that the elevated parameter does
not cause fires or significantly inhibit anaerobic decomposition by killing methanogens.
https://ncconnect.sharcpoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00102/20190426.a l 6.docx 3

The question is based the word"or,"which suggests that only one of the two criteria outlined regarding fires and anaerobic
decomposition. WaRO advised that they consult with the DAQ Central Office and other regional offices. A March 25,2013
EPA Applicability Determination 0400033 (hops://ncconnect.sharepoint.com/sites/DAO-
WaRO/FacilitiesB ertie08/00102/EPA%20ADI%20%20Landfill%200xygen%200perating%20Value%2003-25-13.pdf),
both criteria have to be met to allow a higher operating value. Part of the discussion of the HOV noted that Republic has a
facility in Indiana that has 18 wells with permitted temperature limit of 201F.
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 observed the records for quarterly surface monitoring of methane.The routes are explained in the design plan. The semi-
annual report covering July 1,2017 thru December 31,2017 and collection data through July 2018 have indicated that
methane exceedances have occurred during that period. 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 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 thru December 2018 time-
period was received on January 29,2019. WaRO's review of the report 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
https://ncconnect.sharcpoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00102/20190426.a16.docx 4

ECRSWL is required to take suitable measures to control odorous emissions. No odor was detected during inspection 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 July thru December 2018 time-period was
received on January 29,2019. WaRO's review of the report indicates compliance.
2Q.0317—Avoidance Conditions(2D.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 last semi-annual report covering the July thru December 2018 time-period was received on January 29,2019. WaRO's
review of the report 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.
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 operate in compliance with all applicable Air Quality regulations and permit conditions at the time of
inspection.
https://ncconnect.sharcpoint.com/sites/DAQ-WaRO/Facilities/BertieO8/00102/20190426.a l 6.docx 5