AQ_F_0400052_20191014_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: 10/28/2019
Facility Data Permit Data
Anson County Waste Management Facility Permit 09835/T04
375 Dozer Drive Issued 2/26/2019
PoMon,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 63: Subpart 6C
Tyler Fitzgerald Tyler Fitzgerald Lana Brown NSPS: Subpart XXX
District Manager District Manager Eastern Region Env.
[phone] [phone] Manager
[phone]
Compliance Data
Comments:
Inspection Date 10/14/2019
Inspector's Name Jeffrey D. Cole
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: /!/�Z��/9 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
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
2016 0.9900 0.6700 4.03 2.35 21.91 0.9900 1413.25
*Highest HAP Emitted(inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
12/28/2018 Compliance Method 25C,Method 3C CD-1

I. Location/Directions: Anson County Waste Management Facility is located at 375 Dozer Drive,
near Polkton,NC, Anson County. Directions: From FRO,take Raeford Road, Hwy 401, south to
Wagram,—32 miles. Just past Wagram,torn 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.
II. 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(MS W) landfill located near the town of Polkton,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 II 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 has submitted a permit application to include NSPS XXX into their permit. That permit
action is under review in Raleigh Central Office Permit Section.

IV. Current throughputs:The facility is currently accepting MS W at an average rate of 2,800 TPD.
The average LF Gas Flow rate was recorded at 760 acfm during this inspection.
V. Current Permitted Emission Sources
Emission Source ID Emission Source Description Control Device DescControl System
Ib escri tion
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 and (2500 scfm, 75 million
annual average of 2,800 TPD flaring around 626 Btu per hour heat input
scfm LFG on @ 500 Btu/ft heat rate
inspection 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 October 14,2018, I,Jeffrey Cole and Mitchell Revels of NC DAQ
FRO met with Tyler Fitzgerald,District Manager,for an Air Quality TV permit inspection. Mr.
Dustin Towne, a newly hired operator at the facility,was also present during the inspection.
Presently the Air Quality permit is relativly 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. I presented the Facfinder to Mr. Fitzgerald and he noted a small
change to the contacts was needed. This change has been made in IBEAM. The following items
were discussed:
• We discussed the newly issued TV permit. I asked if they had any questions about
the permit. Mr. Fitzgerald indicated that he had no questions.
• We discussed the waste acceptance rate. Mr. Fitzgerald indicated the rate is up
around 2,800 TPD and remarked that as a very good rate for the facility.
• We confirmed that since the facility to tested below 34 mega grams of NMOC in its
recently completed Tier II testing that the requirement to produce a design plan under
NSPS XXX was not indicated.
• Mr. Fitzgerald stated that the facility had dewatered their gas wells in April of 2019.
• The present GCCS installed voluntarily before required by NSPS XXX.
• The facility plans to install 5 new gas wells between December 2019 and January
2020.
Inspection Summary: Mr. Fitzgerald stated that the flare operates approximately with a flow of
600 to 700 scfm with no opacity. Mr. Fitzgerald indicated that the control system is engineered
to close and not vent to atmosphere during flare downtime. This was verified by observing the

physical design of the system(no bypass vent and the presences of auto shut-off valve). The
wellheads appeared to be well maintained and no LF gas odor was detected, a good indication of
no leaks. The LFG flow recorder was observed and was recording around 626 scfin.
I reminded Mr. Fitzgerald that when the GCCS is required by NSPS (when the LG generation
surpasses 50 Mg/year NMOC),the complete GCCS system will need to meet all requirements
and gas flow recording is included as a requirement. This facility will also be subject to
NESHAP AAAA when it surpasses the 50 Mg/year NMOC. Note: The Anson County Waste
Management Facility has tested-out of the required GCCS thru 2022
VIL 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: The flare was operating a 0%opacity during the
inspection.
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. [I5A 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 7/30/19 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: I did not observe any objectionable odors beyond the
property boundary. Mr. Fitzgerald stated that no odor complaints had been received by the
facility. No odor complaints about this facility have been received by the FRO.
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<�ollutant mssro tl imif '
. ,..;:ua ])� CC1ptlQiitf= ':� �` OffiC.
Benzene 108.62 lb/yr
Landfill(ES-1) Hydrogen chloride
Fugitive emissions Hydrogen sulfide { 3.16 lb/day
Vinyl chloride �- -96.56 lb/yr
M
Benzene ( 5.26 lb/yr
Candlestick flare(CD-1) Hydrogen chloride 6.59 lb/hr
Hydrogen sulfide 0.15 lb/day i
Vinyl chloride F 4.66 lb/yr
APPEARS IN COMPLIANCE: Modeling was based on LANDGEM-generated flow rates
at peak generation rates without control and indicated less than 28%AAL for any TAP.
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: Per the permit review and Toxic evaluated 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.
7. REPORTING REQUIREMENTS: GENERAL CONDITION P- Compliance certification
requires annual submittal of compliance certification report, due by March f of each year.
APPEARS IN COMPLIANCE: The recent ACC was received on January 29, 2019 and has
been reviewed and approved by DAQ FRO. All reports have been received by due date of
March 1 of each year and reviewed with no deviations.
8. REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND PERMIT
DEVIATIONS: GENERAL CONDITIONS LA and LB [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.
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.
10. 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).
11. Non-Compliance History Since 2010:None
VIII. Comments and Compliance Statement: Anson County Waste Management facility
appears in compliance based on this inspection and the data summary contained in the NSPS
W W W Tier 2 performed in December 2018 and into January 2019.
PINK SHEET ADDITIONS: None.
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