August 3, 2006
Mr. Tom Flannagan, General Manager
Uwharrie Regional Landfill
500 Landfill Road
Mount Gilead, North Carolina 27306 8935
Subject: Uwharrie Regional Landfill, Troy, Montgomery County, North Carolina, Air Permit 08826T05, Facility ID 06-62-00052
Protocol for Testing the Active Landfill Gas Collection System Open Flare (ID No. CD 01) to
Determine Nonmethane Organic Compounds (NMOC) Reduction Efficiency or NMOC Emission Concentration Measurement, NSPS Subpart WWW
To be performed by Carlson Environmental Consultants, PC
Proposed Test Date: Week of August 14, 2006
Dear Mr. Flannagan:
The emissions test protocol for the subject open flare has been reviewed. The methods and procedures to be used are those listed in 40 CFR Part 60, Subpart WWW, Standards of Performance for Municipal Solid Waste Landfills and 40 CFR Part 60.18, General Control Device Requirements. The subject non assisted flare is an open flare designs that cannot be measured for NMOC reduction efficiency or NMOC emission concentration measurement due to the absence of an enclosed exhaust area. The table below lists the pollutants and test methods:
| Target Pollutant | Proposed Test Method |
| Combustion Gas Exit Velocity | U.S. EPA Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate(Type S Pitot Tube) (3 runs of 30 minutes each concurrent to the U.S. EPA Method 22 testing) |
| Combustion Gas Net Heating Value / Methane Content | U.S. EPA Method 3C: Determination of Carbon Dioxide, Methane, Nitrogen, and Oxygen from Stationary Sources with U.S. Method 22 (3 runs of 30 minutes each concurrent to the U.S. EPA Method 22 testing)Note 3 runs using a separate canister for each run’s collection will be required. |
| Visible Emissions | U.S. EPA Method 22: Visual Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares. Note that VE emissions must not to exceed a total of 5 minutes during any 2 consecutive hours. (The observation period is 2 hours) |
Uwharrie Regional Landfill shall be responsible for ensuring, within the limits of practicality, that the gas collection system is operated at or near their maximum normal process rate. Based on the current process, the maximum normal process rate for the subject flare is 2,500 scfm of landfill gas. The final test report must include information documenting that the near maximum normal requirement was met during the test period (i.e., at or above approximately 90 percent).
The test protocol is approved as represented in the table. Approval of the testing proposals does not exempt the tester, in any way, from the minimum requirements of the applicable test methods. Any deviations from the applicable methodologies remain subject to the approval of the Division of Air Quality and the U.S. EPA. If there are any additional questions concerning this matter, please contact me at (919) 715-0251 or at gregg.oneal@ncmail.net.
Sincerely,
Thomas G. O'Neal, III, P.E.
Environmental Engineer
cc:
Drew Isenhour, Republic Services of North Carolina, LLC, Hickory, NC
Kristofer L. Carlson, P.E., Carlson Environmental Consultants, PC, Monroe, NC
Steven Vozzo, Fayetteville Regional Office
SSCB File via Michael Y. Aldridge
Central Files, Montgomery County
IBEAM Documents 6200052 (Filename: cec0806T.doc) Tracking No. 2006-187ST