Document 8O3kqwYRY2KbzvdEogJebk76e

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: July 1, 2021 CLEAN AIR ACT INSPECTION REPORT Southeast Berrien County Landfill, Niles, Michigan Daniel Heins, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Southeast Berrien County Landfill (SEBCL) Facility Location: 1540 Mayflower Road, Niles, MI 49120 Date of Inspection: Virtual Opening Conference: May 4, 2021 On Site Inspection: May 6, 2021 Closing Conference: May 6, 2021 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist 2. Vicky Mei, Environmental Engineer 3. Emma Leeds, Environmental Engineer Other Attendees: 1. Emily Stoler, Environmental Compliance Manager - SEBCL 2. Tyler Ganus, General Manager - SEBCL 3. Josh Eagleson, Senior Environmental Technician - SEBCL 4. Jeff Benya, Environmental Quality Analyst - Michigan Environment, Great Lakes, & Energy (EGLE) 5. Mike Kovalchick, Environmental Engineer - EGLE 6. Matt Deskins, Environmental Quality Analyst - EGLE Contact Email Address: estoler@sebclandfill.com Purpose of Inspection: Clean Air Act compliance Facility Type: Muncipal solid waste (MSW) landfill Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart WWW; 40 C.F.R. Part 63, Subpart AAAA, Title V Permit Requirements Virtual Conference (5/4) Start Time: 14:00 Virtual Conference (5/4) End Time: 15:30 On Site (5/6) Arrival Time: 9:30 On Site (5/6) Departure Time: 13:00 Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from SEBC representatives. Process Description: The Southeast Berrien County Landfill (the Landfill) is a 160-acre municipal solid waste landfill that opened in 1972. The Landfill is owned by five municipalities and has 20 employees. The Landfill accepts up to about 900 tons of waste per day, consisting of approximately 80% MSW, with the rest including a mix of construction and demolition waste, sludges, and industrial waste. The Landfill is currently in phase 6, with an expected 13 years remaining in its lifespan. If a phase 7 expansion is approved, another 20 years would be added. There is final cover on phases 2, 3, and parts of 4 and 5. Leachate is actively collected, pretreated for ammonia, and flows to the Buchanan Publicly Owned Treatment Works. There are approximately 105 gas wells, both vertical and horizontal. After collection, landfill gas (LFG) is sent to a gas to energy plant with three Caterpillar 3520 landfill gas engines, managed by North American Natural Resources. LFG can also be flared by an open Zink flare, which only occasionally runs. Staff Interview: To address watered-in wells, the Landfill has added dewatering pumps to 26 wells since the 2019 US EPA inspection. This resulted in an improvement in gas collection, but there have not been any re-measurements of water levels since pump installation. Page 2 of 5 Surface emissions monitoring (SEM) is conducted in-house by a technician at the Landfill using an SEM5000 Portable Methane Detector. SEM surveys include monitoring at cover penetrations. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA and EGLE conducted a limited SEM survey of the facility. EPA made observations with a Forward Looking Infrared (FLIR) camera. Gas leakage was in some locations visible on the FLIR camera, and a total of 22 points were found to have surface methane concentrations in excess of 500 parts per million (ppm). Distressed vegetation, exposed waste, and an animal burrow were observed. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. RECORDS REVIEW Requested and reviewed prior to inspection: Cover integrity reports, from September 2019 to present PDF of the most current depiction/map of their gas collection and control system(GCCS) Map depiction of where their current working active face is located Current New Source Performance Standard (NSPS) SubpartWWW Landfill GCCS Design Plan NSPS SEM reports (including any follow-up monitoring) from 4th Quarter 2019 to present with all associated recorded data Most recent depth to water measurements for each well with percent of perforation available, in a spreadsheet format Wellhead parameters monitoring (in spreadsheet format), including records for correction of any exceedances, from September 2019 to present Control device parameter monitoring (e.g. temperature and LFG flow to flare) in a spreadsheet format, from September 2019 to present List of any wells installed from September 2019 to present with reason for installation Waste accepted by category over the past year, in a spreadsheet format if available Any performance tests for any control devices on site conducted from September 2019 to present, including but not limited to flares and any gas-to-energy engines/turbines (if not already available via https://www.deq.state.mi.us/aps/downloads/SRN/N5432/ ) Any gas sampling test reports (such as for HAP or for sulfur) from September 2019 to present All submitted semi-annual reports from September 2019 to present Page 3 of 5 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Leachate collection system map Dewatering pump preventative maintenance procedure Gas generation data SOP for cover integrity Leachate generation/collection data from September 2019 to present Missing SEM report from prior EPA Section 114 Information Request (2018 Q4) Documentation of exceedance correction and re-monitoring for SEM hits detected by EPA and EGLE Compliance Assistance: EPA and EGLE answered questions about SEM procedure and provided recommendations on more effective methods to address LFG leaks at penetrations. DIGITAL SIGNATURES Digitally signed by DANIEL DANIEL HEINS HEINS Date: 2021.07.01 08:39:07 _____________-_05_'00_' _________________ Daniel Heins, Report Author Digitally signed by ETHAN CHATFIELD EDTaHteA: N20C21H.A07T.F0I2ELD _____________0_7_:36_:5_0_-0_5'0_0_' _____________ Nathan Frank, Section Chief (IL/IN) Page 4 of 5 Facility Name: Southeast Berrien County Landfill Facility Location: 1540 Mayflower Road, Niles, MI 49120 Date of Inspection: May 4 & 6, 2021 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Field Measurement Data Page 5 of 5 Facility Name: Southeast Berrien County Landfill Facility Location: 1540 Mayflower Road, Niles, MI 49120 Date of Inspection: May 4 & 6, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Vicky Mei 2. Archival Record Location: ERC Enf_SoutheastBerrienLandfill_MI_21 Image Number 1 2 3 4 5 6 7 8 9 10 File Name IMG_0305.JPG IMG_0306.JPG IMG_0307.JPG IMG_0308.JPG IMG_0309.JPG IMG_0310.JPG IMG_0311.JPG IMG_0312.JPG MOV_2550.mp4 MOV_2552.mp4 Date/Time (Eastern) 2021-05-06 2021-05-06 2021-05-06 2021-05-06 2021-05-06 2021-05-06 2021-05-06 2021-05-06 2021-05-06 11:14 11:38 11:44 11:45 11:59 11:59 12:05 12:06 11:32 2021-05-06 11:36 Description of Image EPA hit #1 (distressed vegetation) EPA hit #2 (DW50, exposed waste) EPA hit #3 (exposed waste) EPA hit #3 (exposed waste) EPA hit #4 (exposed waste) EPA hit #4 (exposed waste) EPA hit #5 (animal burrow, exposed waste) EPA hit #5 (animal burrow, exposed waste) FLIR video of gas leak adjacent to DW50 (EPA hit #2) FLIR video of gas leak at DW50 (EPA hit #2) Appendices Page 1 of 3 Facility Name: Southeast Berrien County Landfill Facility Location: 1540 Mayflower Road, Niles, MI 49120 Date of Inspection: May 4 & 6, 2021 APPENDIX B: FIELD MEASUREMENT DATA Exceedances detected by EPA ID Description Latitude Longitude EPA 1 EPA 2 EPA 3 EPA 4 EPA 5 East of FPW33, distressed vegetation DW50, within pit surrounding dewatering well West of DW-45 East of DW-22 South of DW-23 (animal burrow) 41.811600 -86.333213 41.810510 -86.333609 41.810089 41.809918 41.810096 -86.333513 -86.334126 -86.334217 A56584 Methane Reading (ppm) 707 4000 1000 977 1050 A56575 Methane Reading (ppm) 508 1450 900 780 750 Exceedances detected by EGLE: ID Description AQD 1 AQD 2 AQD 3 AQD 4 AQD 5 AQD 6 AQD 7 AQD 8 AQD 9 AQD 10 AQD 11 AQD 12 AQD 13 AQD 14 AQD 15 AQD 16 AQD 17 Secondary-4C Secondary riser-3B Leachate clean out-4C 4C P-Trap GW-IOH3 (Watered in well) GW-30 GW-51 GW-52 (Cracks noted in ground around wellhead.) HGP-6 HGP-8 HGP-9 (Watered in horizontal well.) HGP-10 GW-38 GW-46 Forced main marker between GW-45 and GW-46 Forced main marker between GW-45 and GW-46 GW-45 Latitude Longitude 41.812248 41.81226683 41.8121135 41.81214883 41.8121195 -86.3333015 -86.3332015 -86.33289217 -86.3326615 -86.33234533 41.81145117 41.81173017 41.81208617 -86.33197883 -86.33160767 -86.33129817 41.8118795 41.810917 41.81043667 -86.33048483 -86.33015233 -86.3301175 41.80996783 41.808744 41.80965733 41.80975583 -86.33017017 -86.33123783 -86.3327785 -86.33287033 41.80986733 -86.33293567 41.81001883 -86.33300317 Methane Reading (ppm) 1487 892 2671 1422 1459 145,226 662 9128 3385 2276 1578 20,735 1780 854 36,634 3393 5578 Appendices Page 2 of 3 Facility Name: Southeast Berrien County Landfill Facility Location: 1540 Mayflower Road, Niles, MI 49120 Date of Inspection: May 4 & 6, 2021 EPA Calibration Data TVA calibration at 10:00AM. TVA #A56584 TVA #A56575 Methane Reading (ppm) # 1 480 # 2 487 # 3 487 Response Time (s) 4.4 4.4 4.7 Methane Reading (ppm) 486 487 487 Response Time (s) 5.2 4.6 4.5 Calibration gases provided by SEBCL. Air, zero grade, THC < 1 ppm, expiration 09/2021 Methane 500 ppm, expiration 09/2021 Bump check with 500 ppm calibration gas at 12:45 PM. TVA #A56584 TVA #A56575 Methane Reading (ppm) Methane Reading (ppm) # 1 530 481 # 2 529 483 # 3 530 487 The upwind reading was 3 ppm, and the downwind was 9 ppm. These readings were taken by EGLE. Appendices Page 3 of 3