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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretory
MICHAEL ABRACZINSKAS
Director
November 2,2018
Mr.Tyler Fitzgerald
District Manager
Anson County Waste Management Facility
375 Dozer Dr
Polkton,NC 28135-7773
Subject: Anson County Waste Management Facility(ACWMF)
Polkton,Anson County,North Carolina,Air Permit No. 09835T03
Facility ID 0400052,Tracking No. 2018-308ST
Protocol for 5-Year Nonmethane Organic Compounds(NMOC)Tier 2 Emissions Testing of
Municipal Solid Waste Landfill ID No. ES-1 (Phases 1,2,and 3),NSPS Subpart XXX
For a Site-Specific NMOC Concentration and NMOC Emissions Rate
To Be Performed by Franklin Engineers&Consultants,LLC
Proposed Test Dates:December 11 and 12,2018
Dear Mr. Fitzgerald:
The emissions test protocol for the subject landfill has been reviewed. Testing will quantify the NMOC
emissions in accordance with 40 CFR 60 Subpart XXX Standards of Performance for Municipal Solid
Waste Landfills That Commenced Construction, Reconstruction, or Modification After July 17, 2014.
40 CFR 60 Subpart XXX requires sampling of a minimum of 2 probes per hectare of landfill surface area
that has retained waste for at least 2 years. If the landfill area is larger than 25 hectares in area,only
50 samples are required. The table below lists the pollutants and test methods:
Pollutants and Test Methods
Pollutant Standard EPA Method Run Time Notes
Methane, Concurrent with
Nitrogen,and Oxygen --- 3C Composite sampling Method 25C
Landfill Gas: Canister Sampling ES-1
Nonmethane Organic 40 CFR 60 25C Common Header Location
g art XXX orb (surface area that has retained
Sub
Compounds(NMOC) p Composite(from 4 Probes) Waste for at least 2 years)
Note: When sampling at a common header location three individual separate canisters samples must be collected.
When collecting composite samples,an equal volume must be collected from each vent or probe sampled.
The total landfill surface area that has held waste at least 2 years is approximately 55.4 acres
(22.4 hectares). The landfill currently operates a voluntary installed Gas Collection&Control System
(GCCS).The GCCS collects landfill gas(LFG)to a common header and measures this gas flow for
approximately 51 acres(20.6 hectares). The remaining 4.4 acres(1.7 hectares)of landfill area requires a
minimum of 4 evenly distributed sample probes to be installed for the equal volume composite sampling.
The samples are to be analyzed using EPA Methods 3C and 25C. The methods proposed are acceptable.
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North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400
Mr.Tyler Fitzgerald,District Manager
November 2,2018
Page 2(Anson County Waste Management Facility, 5-Year NMOC Tier 2 Landfill Emissions Testing)
The final test report must include a scale plan of the landfill as tested with emission wells and/or probe
locations marked. The wells and/or probes located in each phase area should be tabulated to demonstrate
that the 2 samples per hectare of surface area requirement was met. The final report should clearly
explain how the landfill NMOC results were determined using the proposed sampling procedures and the
40 CFR 60.764(a)&(b)emissions reporting. In addition, data to validate the GCCS flow meter
calibration must be included in the report.
Approval of the proposed methods does not exempt the tester,in any way, from the minimum
requirements of the applicable test methods. Any deviations from the applicable methodologies not
specifically addressed in this letter remain subject to the approval of the Division of Air Quality. At least
15 days prior to the subject test start date,the regional office must be notified in order to arrange for an
observer to be present. If there are questions concerning this matter,please contact me at(919)707-8415
or gregg.oneal(a-),ncdenr.go�.
Sincerely,
s
Thomas G. ONeal,III,P.E.,Environmental Engineer
Division of Air Quality,NCDEQ
cc: Juene Franklin,P.E.,Franklin Engineers&Consultants,LLC -Pearland,TX
Heather Carter,Fayetteville Regional Office
Central Files,Anson County
IBEAM Documents -0400052