Document 2Jd1LRr7q0EZzj6mVNRp0eeB7

Region 2 Enforcement & Compliance Assurance Division Air Compliance Branch CAA Inspection Report Inspection Date: 8/9/2022 Facility Name: Burlington County Resource and Recovery Complex (BCRRC) Facility Address: 2098 Burlington Columbus Rd, Bordentown, NJ 08505 ICIS-Air ID #: NJ0000003400545317 Facility Contact: Jerome Sheehan, Director of Solid Waste, jsheehan@co.burlington.nj.us, 609-499-1001 EPA Lead Inspector :Victor Tu, Environmental Engineer, ECAD/ACB, 212-637-3476 EPA Asst. Inspector :Phillip Ritz, Environmental Scientist, ECAD/ACB, 212-637-4064 State Inspector(s): State inspector name, title, phone number. Other Inspector(s): Omer Sohail, EPA Environmental Engineer, LSASD -MAB, 732-321-4461 Other Inspector(s): Supriya Rao, EPA Environmental Engineer, LSASD-MAB, 732-321-3622 Other Inspector(s): Harish Patel, Team leader, ECAD/ACB, 212-637-4046 Background The County owns the Burlington County Resource Recovery Complex ("BCRRC") in Florence and Mansfield Townships, New Jersey. The current operator of the site is Waste Management. The Complex is the site of all solid waste processing and disposal activities undertaken by the County pursuant to directives of the New Jersey Solid Waste Management Act. Solid waste from all of the County's forty municipalities is accepted at this facility. The 522-acre tract was selected in 1981 as the site for the Complex which commenced operation in 1989. Current projections anticipate that the Complex will meet the disposal needs of Burlington County until 2027. Pertinent Regulatory Requirements Burlington County Resource and Recovery Complex is subject 40 CFR 60 Subpart XXX -MSW Landfill Regulations, 40 CFR 63 Subpart AAAA -Landfill MACT and has a Title V Operating permit issued by NJDEP. Summary of Observations List of Attendees Jerome Sheehan, Director of Solid Waste -Burlington County LF Joseph Hilla, Site Supervisor -Burlington County LF Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 1 8/9/2022 Laurie E. Van Genderen, District Solid Waste Coordinator -Burlington County LF Eric Peterson, Project Director -SCS Engineers Victor Tu -EPA Environmental Engineer Phil Ritz -EPA Environmental Engineer Harish Patel -EPA Environmental Engineer Omer Sohail -EPA Environmental Engineer Supriya Rao -EPA Environmental Engineer Inspection/Project Description EPA Inspectors contacted BCRRC on Thursday, August 4, 2022, and spoke with Jerome Sheehan. During the call, EPA notified BCRRC that EPA planned to conduct Surface Emission Monitoring at the time of the onsite inspection and requested that BCRRC contact their surface monitoring contractor so they can be present during the inspection. On August 9, 2022, EPA Inspectors Victor Tu, Phil Ritz, Harish Patel, Supriya Rao, and Omer Sohail arrived at BCRRC's offices in Columbus, NJ at approximately 9:30 AM. We were met in their conference rooms by Jerome Sheehan. At a conference room in the Rutgers University Campus building, the EPA inspectors were joined by Joseph Hilla, and Laurie Van Gerderen from BCRRC, and Eric Petersen, BCRRC's outside consultant, from SCS Engineers. Inspector Tu explained that the purpose of EPA's inspection was to conduct surface emissions monitoring (SEM) of the landfill surface, and also to observe any staff or contractors who perform routine surface emissions monitoring and data management. EPA had announced this inspection and had requested that the SEM contractor (SCS Engineers) be available for the inspection. SCS representative indicated that the SEM technicians were not available. During the opening meeting, Mr. Sheehan gave the team an overview of the landfill. The entire site occupies about 522 acres, but the landfill covers only 200 acres. BCRRC has basically 2 landfills -Landfill 1 which started accepting waste in 1989 and was capped in 2001 and Landfill 2 which started accepting waste in 1999. In 2015, BCRRC started filling in the "wedge" between the two landfills. The landfill is owned by Burlington County, but it is operated by Waste Management Inc. Municipal waste is collected from the county. BCRRC also receives mixed wood, which is ground and used as daily cover, together with dirt, glass cullet. No auto fluff is used for daily cover. BCRRC has installed a GCCS to collect the landfill gas (LFG). In the past, BCRRC collected the gas and generated electricity. Currently, BCRRC does not operate any engines (they have been removed), and all collected LFG has been flared in 3 flares on-site as of June 2020. The LFG is not treated before flaring. The LFG energy plant started-up in 2008. In June 2020, the energy plant was shut down due to economics. Also, siloxane buildup on the engines was a concern. Although the LFG energy plant is not operating, the former company is "paying" BCRRC for the LFG collected, and also providing "free" electricity to the Landfill. Operates two (2) enclosed flares and one (1) candle-stick flare; all three flares operate at the same time and are permitted to operate 8760 hours. All three flares were performance tested about 15 years ago. Has 5 blowers -only 4 currently being used Two (2) condensate knock out pots -one each for each landfill cell. No temp exceedances monitored at the wellheads Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 2 8/9/2022  Some wells are flooded with water The leachate from the landfill is gravity-drained by a leachate collection system and stored in a 1-million- gallon tank. The leachate is not treated on-site. The leachate plant was closed in 1996. BCRRC trucks out approx. 130,000 gals/day of leachate and spends about $ 2.0 million per year to ship the leachate off-site. Leachate is sent to Mt Holly WWTP or Florence WWTP. Mr Petersen from SCS Engineers explained how they conduct quarterly SEM at the landfill. He also mentioned that the SCS technicians who conduct SEM were not available for the EPA inspection this week. EPA could not oversee any monitoring equipment calibration observations. Any leaks identified by the contractor are noted and flagged to BCRRC personnel. All repairs are done by BCRRC and re-monitored by SCS Engineers. At about 11:00 AM the EPA team began LDAR monitoring on the Landfill and continued after lunch. Numerous leaks were discovered by the team. The locations and leak concentrations were provided to BCRRC and SCS personnel. We left the facility around 4:00 PM. On August 10, 2022, the EPA inspectors arrived at BCRRC at around 8:45 AM. After a quick recap of the plan for the day, we began SEM of the wellheads. On the south side of Landfill, a significant portion of the top cover had washed away during some recent heavy rainstorms in May and June 2022. BCRRC personnel explained that they were working on repairs and would be completed by 8/13/2022. Also observed some operating data from the three flares. CD-1 (smaller flare) -1699 degrees F; CD-3 (larger flare) -1708 degrees F. The gas flows to each of the flares was as follows: CD-1 -306 scfm; CD-3 -1720 scfm; and CD-8 -954 scfm. During the inspection the candle stick flare stop operating for a few minutes. EPA inspectors noticed this while observing the flare using the FLIR camera. The team then proceeded to the conference room for a close-out meeting. During our closing meeting we requested the following documents: 1. The last stack test report for CD-1 and CD-3 2. Manufacturer's specs for candlestick flare (CD-8). 3. Wellhead GEM monitoring data for the past 2 years 4. Leachate Generation/Recirculation Records for the past 2 years 5. Flare operation data including flowrate, and temperature records for the past 2 years 6. Quarterly Surface Emission Monitoring Report for the past 2 years 7. SEM Re monitoring and Repair Records for the past 2 years 8. Documentation pertaining the cover collapse, i.e., Report to NJ, SEM on the surface, corrective action plan, etc. At the closing meeting, EPA Inspectors indicated that the leaks would need to be repaired and re-monitored as required by the regulations. The list of leaks identified will be provided to BCRRC via email. It was agreed at the closing meeting that required timeframe of the response to repair the leaks identified by EPA will start upon the receipt of EPA's Exceedance Report. The EPA inspectors left the facility around 1:00 PM. Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 3 8/9/2022 Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 4 8/9/2022 Table 1, EPA's Exceedance Report Lead Inspector's Name: Victor Tu 10/26/2022 X Victor Tu Lead Inspector Signed by: VICTOR TU Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 5 8/9/2022 Assisting Inspector's Name: Phillip Ritz 10/26/2022 X Phillip Ritz Assisting Inspector Signed by: PHILLIP RITZ Supervisor's Name: Harish Patel 10/26/2022 X Harish Patel Supervisor Signed by: Environmental Protection Agency Burlington County Resource and Recovery Complex (BCRRC) - NJ0000003400545317 6 8/9/2022