AQ_F_0400052_20181017_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: 10/24/2018
Facility Data Permit Data
Anson County Waste Management Facility Permit 09835/T03
375 Dozer Drive Issued 8/22/2014
Polk-ton,NC 28135 Expires 8/31/2018
Lat: 35d 0.2610m Long: 80d 9.7720m Classification Title V
SIC: 4953/Refuse Systems Permit Status Active
NAICS: 562212/Solid Waste Landfill Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Tyler Fitzgerald Tyler Fitzgerald Lana Brown NSPS: Subpart W W W
District Manager District Manager Eastern Region Env. NSPS: Subpart XXX
[phone] [phone] Manager
[phone]
Compliance Data
Comments: P✓
jY Inspection Date 10/17/2018
Inspector's Name Mitch Revels
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: f �(y_ On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2015 0.8000 0.5500 3.27 2.38 17.77 0.8000 1373.55
* Highest HAP Emitted inpounds)
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

1) 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,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.
2) 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.
3) Description:The Anson County Waste Management Facility(ACWMF)is a municipal solid waste
(MSW)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 11 results indicated an additional
5 years,with no GCCS requirement by Air Regulations NSPS W W W thru 2016. This facility performed
another Tier H test in November 2016 and submitted a test report on December 15,2016. 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 2020.
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
I calculation indicating the NMOC 867.5 Mg/yr. This facility has elected to perform a Tier 2 Test to determine
actual NMOC emissions. This test is scheduled for mid-December 2018. The test protocol has been submitted
and under review by DAQ SSCB in Central Office. The result of this test will determine if the facility test out
of the 34 Mg/yr NMOC threshold contained in NSPS XXX. 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.
4) Current throughputs: The facility is currently accepting MSW at an average rate of 2500 TPD. The
average LF Gas Flow rate was recorded at 500 acfin during this inspection.

5) Current Permitted Emission Sources.
Emission Source ID Emission Source Description Control Device Control System
ID Description
ES-1 One municipal solid waste GCCS-1 * Gas collection and
NSPS Subpart WWW landfill control system
Waste Acceptance Rate of an CD-1 * Candle stick type flare
annual average of 2500 TPD (2500 scfm, 75
Collecting and million Btu per hour
flaring around 500 heat input @ 500
scfm LFG on Btu/ff'heat rate of
inspection date. landfill as)
* Voluntary gas collection and control system (not yet required by 40 CFR 60,Subpart WWW or XXX);
Testing is scheduled in mid-December 2018 to determine NMOC emissions and further action for NSPS
WWW and XXX.
6) Inspection Conference: On October 17,2018,I, Mitchell Revels and Jeffrey Cole,NC DAQ FRO
met with Tyler Fitzgerald,District Manager, for an Air Quality TV permit inspection. Presently the
Air Quality permit is relative 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
W W W and XXX. This was discussed in the meeting how that the upcoming Tier II test result will
determine the next step for this facility in respect to NSPS W W W and XXX. Mr.Fitzgerald verified
the contacts based on FACFINDER printout.
a) We discussed the TV permit. I asked if they had any questions about the permit. Mr.
Fitzgerald indicated that he had no questions.
b) We discussed the waste acceptance rate.Mr. Fitzgerald indicated the rate is up around 2500
TPD and remarked that as a good rate for the facility.
c) We discussed that requirement for a design plan should the facility not be able to test below
34 mega grams of NMOC.
d) The present GCCS installed voluntarily before required by NSPS W W W.
e) The facility plans to install 5 new gas wells in the next 12 months.
f) Mr. Fitzgerald indicated that Mr.Juene Franklin of Franklin Engineers and Consultants, LLC
is handling the Air Quality issues for him.
7) Inspection Summary: Mr. Fitzgerald stated that the flare operates approximately with a flow of
500-550 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 recording around 500 scfm. I indicated that when the GCCS is
required by NSPS,the complete 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 2020.
8) Stipulation Review for Section 2- Specific Limitations and Conditions:

A. 15A NCAC 2D .0524,40 CFR Part 60, Subpart W W W:New Source Performance
Standards for Municipal Solid Waste Landfills
APPEARS IN COMPLIANCE:
This facility is subject to NSPS W W W,however in November 2016,the facility performed a
Tier 2 Test as outlined in 60.754 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 2020. The facility submitted a 5-year report demonstrating
compliance.Therefore,an annual report is not required. The calculated NMOC for the fifth
year in 2020 is 49.28 Mgbg.NMOC at a flow rate of 615 scfin. When 50 Mg/yr. of NMOC
is exceeded,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 pas 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 facility is required to submit a semiannual summary report of the monitoring and
recordkeeping activities and indicate if there are any deviation. All reports have been
received with no deviations indicated.
B. 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-I)shall not exceed 2.3 pounds per million Btu heat input.
Appears in Compliance. The AP42 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.
C. 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. Opacity from the flare was 0%.
D. 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 and Mr. Fitzgerald stated that no odor complaints had been received by the facility.
E. 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
Description Toxic Air Pollutant Emission
Landfill(ES-1) Benzene 63.55lbs/ r
Fugitive emissions Hydrogen chloride -------------
Hydrogen sulfide 1.841bs/da

Vinyl chloride 56.34 lbs/ r
Candlestick flare(CD-1) Benzene 3.8 lbs/ r
Hydrogen chloride 0.59 Ibs/hr
Hydrogen sulfide 0.11 lbs/da
Vinyl chloride 4.51 lbs/yr
Appears in Compliance. Modeling was based on LANDGEM-generated flow rates at peak
generation rates without control and indicated less than 7%AAL for any TAP.
F. 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
2014, HCL,Benzene,Hydrogen sulfide,and Vinyl chloride emission were modeled 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. This
facility will become subject to NESHAP AAAA when the facility came no longer test out of
50 Mega grams 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.
9) Reporting requirements: General Condition P-Compliance certification requires annual
submittal of compliance certification report, due by March 1 of each year.
Appear in Compliance-The recent ACC was received on January 30,2018 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.
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) Permit Renewal[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.
Appear in Compliance: The Air Pemrit expiration date for the present permit,Air Permit No.9835T03,was
August 31,2018. The facility submitted a permit renewal on November 15,2017. This permit renewal
application was submitted before 90 days of expiration and is in review in DAQ central Office.
12) Reporting Requirements for Excess Emissions and Permit Deviations 115A NCAC 2D.0535(t)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 have occurred,and therefore
no notification has been required.

13) Non-Compliance History Since 2010:None
14) Comments and Compliance Statement: Anson County Waste Management facility
Appears in Compliance: Based on inspection and the data summary contained in the NSPS
W W W Tier 2 performed on November 2016.
PINK SHEET ADDITIONS: None.
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