Document 93ExVdMk8Y96MEjaKVgwmyxJ6

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCMENT AND COMPLIANCE ASSURANCE DATE: SUBJECT: FROM: THRU: TO: See date of Section Chief signature CLEAN AIR ACT INSPECTION REPORT Waste Connections Seabreeze Environmental Landfill, Angleton, TX Daniel Heins, Environmental Scientist Stationary Source Enforcement Branch, EPA OECA Gregory Fried, Branch Chief Stationary Source Enforcement Branch, EPA OECA File BASIC INFORMATION Facility Name: Seabreeze Environmental Landfill Facility Location: 10310 FM 528 Road, Angleton, TX 77516 Date of Inspection: On Site Inspection: March 16, 2023 Virtual Conference: April 21, 2023 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist, EPA OECA a,b 2. Daniel Hoyt, Environmental Engineer, EPA OECA b 3. Colleen McCarthy, Life Scientist, EPA Region 6 b 4. Kenneth McPherson, Life Scientist, EPA Region 6 a,b 5. Benjamin Rosenthal, Physical Scientist, EPA Region 6 a,b 6. Jamie Lee, Office of Regional Counsel, EPA Region 6 a Other Attendees: 1. Dave Matthews, District Manager, Seabreeze Recovery, Inc a,b 2. Brett O'Conner, Southern Region Engineering Manager, Waste Connections of Texas, LLC a 3. Nikki Crew, Compliance Manager, Waste Connections of Texas, LLC a 4. Gary Bartels, Regional Engineer, Waste Connections of Texas, LLC a 5. Dillon Hoppe, Regional Engineer, Waste Connections of Texas LLC a 6. John Perkey, Vice President/Deputy General Counsel, Waste Connections US, Inc a 7. Sarah Phillips, Environmental Compliance Manager, Waste Connections US, Inc a 8. Joe Ortiz, SCS Engineers b Page 1 of 14 9. Ben Ruiz, SCS Engineers b 10. Jake Stevens, SCS Engineers b a Attended conference b Attended surface emissions monitoring (SEM) Contact Email Address: David.Matthews@WasteConnections.com Purpose of Inspection: Surface monitoring and partial compliance evaluation for the Clean Air Act Facility Type: Muncipal solid waste (MSW) landfill Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart XXX; 40 C.F.R. Part 63, Subpart AAAA; On Site (3/16) Arrival Time: 09:00 Central Time On Site (3/16) Departure Time: 13:30 Central Time Virtual Conference (4/21) Start Time: 13:00 Central Time Virtual Conference (4/21) End Time: 15:00 Central Time Inspection Type: Unannounced Inspection Announced Inspection SITE OVERVIEW Unless otherwise stated, the following information was obtained verbally from Waste Connections representatives, during the virtual conference. Company Ownership: As provided by email after the conference. The Seabreeze Landfill ("the Landfill") is officially operated as Seabreeze Recovery, Inc. This is a subsidiary of Waste Connections US, Inc., in turn a subsidiary of Waste Connections US Holdings, Inc., the top-level US-based entity. The ultimate parent entity is Waste Connections, Inc., based in Canada. John Perkey explained that Waste Connections of Texas serves as the Waste Connections Southern Region administrative entity. Waste Connections acquired the Seabreeze Landfill in 2009 as part of the divestitures associated with Republic Service's acquisition of Allied Waste. Operations Overview: The Landfill began operations in the 1960s. Sector 1 refers to the pre-RCRA subtitle D operations without a modern liner. It is capped and closed, and together with Sector 2 make the southern hill of the Landfill (see overview map, attached). The northern hill of the Landfill is all post-RCRA and lined. There is a slough of water between the two hills. Liner type is variable, Page 2 of 14 using a class 1 liner profile typically with underdrain, clay, and plastic with leachate collection. Sector 2 was identified as most likely having a clay/plastic liner. The site is permitted for 417 acres, with 283.7 acres constructed to date between both the north and south hills. The south hill has 120.4 acres of evapotranspirative cap. There is no final cover on the northern hill. Approximately four acres is under daily cover. No waste types are used as alternative daily cover, just spray-on daily covers (with tarps also approved). For intermediate cover, outer slopes are 4' of clay, with intermediate slopes and the top deck with a minimum of 1' of clay/soils. The Landfill receives 3,500 to 4,500 tons per day of waste. Approximately 60% is MSW, with the remainder being various special wastes. Special wastes include petroleum contaminated soil (approximately 5% of total waste), refuse from industrial sites, and approximately 20% various sludges (such as wastewater treatment plant sludge). The site does solidify liquid wastes. The Landfill receives small amounts of construction and demolition waste. Gas collection is primarily through vertical wells, though horizontals are sometimes utilized when building out an area. Wells are typically installed within a year or two of waste deposition. Gas is primarily routed to a separately permitted high BTU renewable natural gas plant, owned and operated by DTE. Waste Connections has a flare that can be utilized by DTE or control the landfill gas directly. The candlestick flare has a capacity of 4000 or 5000 scfm. There are two blowers. All gas goes to a common header. SITE TOUR -- MARCH 16, 2023 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 Asked the company to identify CBI Data Collected and Observations: EPA conducted an SEM survey of part of the facility. Monitoring was ended early due to the arrival of rain. There were high winds on the day of the inspection. EPA used three ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020) to perform EPA Reference Method 21 for the SEM. Dan Heins, Kenneth McPherson, and Ben Rosenthal each made measurements for EPA. SCS was on site to perform quarterly monitoring. The SCS technicians were using SEM5000 instruments. After discussing with Waste Connections and SCS, EPA split in to two monitoring teams, each accompanied by one of the SCS technicians who could provide confirmation readings of the EPA measurements. EPA inspectors identified 61 exceedances of the surface methane standard, all of which were confirmed by the SCS technicians. See Appendix B for location and description of measurements Page 3 of 14 and map of exceedances. Exceedances were primarily found at penetrations, in exposed waste, and in areas of erosion. Parts of the top deck of the hill were in a state of construction, with DTE adding gas collection wells. EPA asked Waste Connections to identify which exceedances were affected by active construction work. Waste Connections highlighted six exceedances in a document provided via email after the inspection. Independent of the areas affected by construction, EPA documented eroded cover and exposed waste throughout the survey area. Photos and/or Videos: were taken during the inspection. See Appendix A. Field Measurements: were taken during this inspection. See Appendix B. INSPECTION CONFERENCE -- APRIL 21, 2023 Provided U.S. EPA point of contact to the facility Asked the company to identify CBI EPA showed facility representatives a map of the path walked during the on-site SEM survey and the exceedances detected. Staff Interview: EPA inquired as to what level of involvement each conference attendee had directly in the operations of the landfill. David Matthews was the only one who reports to the facility directly. Dillon Hoppe and Gary Bartels work on multiple sites in Texas, including Seabreeze. Brett O'Conner, Dillon Hoppe, Gary Bartels, and David Matthews are all involved in decision making regarding contracting work on site. As Waste Connections has a corporate headquarters nearby, it is readily visited by corporate employees as well. The Landfill design capacity was increased in 2019 and is approximately 64 million cubic yards. The site calculated an uncontrolled non-methane organic compound emission rate of above 50 megagrams and became subject to full gas collection and control system requirements more than five years ago. The GCCS has been in place since at least when it was owned by Allied Waste. The site has approximately 22 more years of capacity pending waste acceptance rates, and has capacity for further expansion. The gas collection system on the Landfill is part of the Landfill's permit and Clean Air Act obligations, however it is managed by personnel from DTE in support of the gas plant. No DTE representatives were on the call. Approximately 60 to 70% of the wells have dewatering pumps. DTE does checks on the dewatering of wells, though none of the Waste Connections staff could state how frequently this happened. New wells are typically installed with dewatering pumps. Page 4 of 14 When asked approximately how much gas is collected from each landfill hill, the Waste Connection staff stated that they would need to check with DTE. Gas collection wells are manually tuned by DTE personnel, and tuning activity often occurs more frequently than monthly to try to optimize collection for the gas plant. All wellhead adjustments are logged. There are DTE staff dedicated full time to management of the GCCS. Part of the task of wellfield management is to ensure oxygen/nitrogen levels are managed. EPA asked if the site was demonstrating compliance with the NSPS/EG via the NESHAP wellhead monitoring requirements and what wellhead parameters they were using for temperature. None of the Waste Connections staff on the call were able to provide an answer. Waste Connections was unaware of any wells operating above 145 degrees Fahrenheit and that temperature exceedances are rare. They were uncertain if there were active Higher Operating Values approved for any wells. Waste Connections works with DTE to determine need for expansions of the wellfield. The Landfill will accept white goods that potentially contained ozone depleting substances, provided that there is record of refrigerant removal from a certified technician. The Landfill accepts asbestos waste, and they keep a map of where it has been deposited. Waste Connections uses SCS for their Part 98 Subpart HH greenhouse gas reporting. EPA asked if there was a reason the Facility changed from reporting estimated emissions based on modeled generation (as it had through 2019) to reporting based on methane recovery and estimated collection efficiency (reporting years 2020 and 2021). EPA noted the sharp difference between the estimates, with the 2021 report showing 693,196 metric tons of CO2 equivalent using the former method and only 89,561 metric tons of CO2 equivalent by the latter. Waste Connections staff stated that they would need to look into that decision making and follow up. SCS performs SEM at the landfill. They send Waste Connections the exceedance table day-of and include a map of the coverage. Corrective actions are grading/clay addition if erosion, if the exceedance is directly at the well then tuning may be done by DTE. Sometimes wellheads may be given boots, which would involve coordination between Waste Connections and DTE. EPA asked about the use of the dangerous areas exemption, noting that reports indicated high vegetation was cited as a reason for excluding significant acreage of the landfill from surface monitoring. Waste Connections staff stated that if the grass is too high there is a risk of snakes and that ultimately they defer to SCS personnel to make decisions about monitoring safety and document areas not monitored in the report. EPA confirmed with Waste Connections that they do have lawn mowing equipment on site. Records reviewed: Table of re-monitoring and corrective actions for exceedances measured during the inspection (via email) Page 5 of 14 o All exceedances addressed by soil addition and compaction, with the exception of two wells that were mid-construction, which were addressed by completing construction. Seabreeze Recovery Inc Parent Company Disclosure (via email) Requested documents: After discussing preference between a Section 114 Request For Information Letter and an emailed list of documents associated with the inspection, Waste Connections expressed a preference for the latter. Concerns: EPA observed erosion and exposed waste over much of the survey area EPA found a significantly higher rate of surface exceedances in the survey area than had been documented in recent SEM surveys EPA expressed concern that because high grass is something that could be readily resolved by the Facility in preparation for surface monitoring that it should not be cited as a dangerous area exempt from monitoring, and that it has not seen that practice at other landfills in similar climates. DIGITAL SIGNATURES _________________________________ Daniel Heins, Lead Inspector Spina, Digitally signed by Spina, Providence Providence Date: 2023.06.20 14:12:51 -04'00' on behalf of __________________________________ Gregory Fried, Supervisor Page 6 of 14 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Field Measurement Page 7 of 14 APPENDIX A: DIGITAL IMAGE LOG Inspector Names: Colleen McCarthy & Dan Hoyt Archival Record Location: US EPA SharePoint Image # 1 2 File Name IMG_4043.JPG IMG_4044.JPG Date and Time (Central) 2023:03:16 10:23:56 2023:03:16 10:28:51 3 IMG_4045.JPG 2023:03:16 10:33:31 4 IMG_4046.JPG 2023:03:16 10:43:01 5 IMG_4047.JPG 2023:03:16 10:52:14 6 IMG_4048.JPG 2023:03:16 10:55:01 7 IMG_4049.JPG 2023:03:16 10:56:25 8 IMG_4050.JPG 2023:03:16 10:56:57 9 IMG_4051.JPG 2023:03:16 11:10:52 10 IMG_4052.JPG 2023:03:16 11:12:13 11 IMG_4053.JPG 2023:03:16 11:13:44 12 IMG_4054.JPG 2023:03:16 11:16:22 13 IMG_4055.JPG 2023:03:16 11:18:13 14 IMG_4057.JPG 2023:03:16 11:21:12 15 IMG_4058.JPG 2023:03:16 11:24:20 16 IMG_4059.JPG 2023:03:16 11:35:28 17 IMG_4060.JPG 2023:03:16 11:39:06 18 IMG_4061.JPG 2023:03:16 11:45:44 19 IMG_4062.JPG 2023:03:16 11:49:17 20 IMG_4063.JPG 2023:03:16 11:50:52 21 IMG_4064.JPG 2023:03:16 12:00:29 22 IMG_4065.JPG 2023:03:16 12:02:46 23 IMG_4066.JPG 2023:03:16 12:04:56 24 IMG_4067.JPG 2023:03:16 12:12:30 25 IMG_4068.JPG 2023:03:16 12:15:08 26 IMG_4069.JPG 2023:03:16 12:17:30 Coordinates Description of Image 29.085908, -95.357186 29.085833, -95.357025 29.085831, -95.357017 29.085928, -95.356392 29.086175, -95.355889 29.086503, -95.356072 29.086406, -95.355958 29.0864, -95.355964 29.086983, -95.356117 29.087353, -95.356217 29.087019, -95.356164 29.087111, -95.356117 29.087114, -95.356108 29.087278, -95.356231 29.087417, -95.356231 29.087672, -95.356561 29.087889, -95.356567 29.087922, -95.356636 29.088089, -95.356514 29.088161, -95.356736 29.088681, -95.356439 29.088819, 95.356522 29.088944, 95.356544 29.088686, -95.356178 29.049833, -95.3526 29.087872, -95.355981 Erosion under piping, A1 Erosion/soil discoloration, A2 Erosion/exposed waste, A3 Well 258 surrounded by exposed waste, A4 GW 261 w/ nearby erosion/waste, A5 Tire penetrating cover, A6 Cracks in bare soil, A7 Cracks in bare soil, A7 Cracks in soil, A8 GW189, exposed waste, A9 Exposed waste/erosion gulley and discolored soil, A10 Erosion gulley, A11 GW187A, exposed waste visible, A12 Soil cracks, A13 bare soil A14 GW253, A15 GW108B w/ gap, A16 Exposed waste, A17 GW 283, A18 Exposed waste, erosion, discolored soil, A19 Well under construction, A21 Erosion gulley, A22 Erosion gulley, discolored soil, A23 GW284 and nearby exposed waste A25 GW176A, A26 GW195A, A27 Page 8 of 14 Image # 27 28 File Name IMG_4070.JPG IMG_4071.JPG Date and Time (Central) 2023:03:16 12:27:28 2023:03:16 12:28:46 29 IMG_4072.JPG 2023:03:16 12:31:02 30 IMG_4073.JPG 2023:03:16 12:35:05 31 IMG_4074.JPG 2023:03:16 12:43:14 32 IMG_4075.JPG 2023:03:16 12:49:37 33 R0010044.JPG 2023:03:16 10:22:26 34 R0010045.JPG 2023:03:16 10:26:56 35 R0010046.JPG 2023:03:16 10:33:01 36 R0010047.JPG 2023:03:16 10:44:36 37 R0010048.JPG 2023:03:16 10:50:42 38 R0010049.JPG 2023:03:16 11:15:41 39 R0010050.JPG 2023:03:16 11:28:02 40 R0010051.JPG 2023:03:16 11:32:54 41 R0010052.JPG 2023:03:16 11:43:58 42 R0010053.JPG 2023:03:16 11:46:28 43 R0010054.JPG 2023:03:16 11:54:37 44 R0010055.JPG 2023:03:16 12:03:32 45 R0010056.JPG 2023:03:16 12:06:25 46 R0010057.JPG 2023:03:16 12:11:01 47 R0010058.JPG 2023:03:16 12:15:50 48 R0010059.JPG 2023:03:16 12:26:07 49 R0010060.JPG 2023:03:16 12:29:22 50 R0010061.JPG 2023:03:16 12:31:28 51 R0010062.JPG 2023:03:16 12:33:41 52 R0010063.JPG 2023:03:16 12:40:25 53 R0010064.JPG 2023:03:16 12:47:37 Coordinates Description of Image 29.086653, -95.355522 29.086325, -95.355522 29.086158, -95.355606 29.085858, -95.355858 29.086161, -95.355025 29.086194, -95.355239 [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] [Non GPS Camera] GW170A, A30 Mound with waste and vegetation growing on top GW165A, exposed waste, A31 Well under construction, A32 GW264, A33 Gulley and disoclored soil, A37 Riser, B1 Discolored soils and cracks/erosion, B2 Discolored soils and cracks/erosion, B3 Erosion and discolored soils, B4 Well 101, B5 Distressed vegetation, B6 Riser with unsealed cap, B7 Erosion and exposed waste, B8 Penetration, erosion, B9 Erosion, B10 GW237, B11 GW111B, exposed waste, B12 GW178A, exposed waste, B13 GW285, B14 GW281, erosion rills, B15 GW254, B16 GW278, exposed waste, B17 GW278A, nearby exposed waste, B18 GW275A, B19 GW164A, exposed waste, B20 GW140B (active installation) B22 Page 9 of 14 APPENDIX B: FIELD MEASUREMENT DATA Measured Exceedances Flag EPA Contractor Reading Reading A1 1,100 1,170 A2 2,800 1,340 A3 1,000 1,340 A4 1,200 1,000 A5 2,600 1,900 A6 1,100 870 A7 1,100 870 A8 1,200 9,600 A9 900 3,000 A10 2,300 1,000 A11 710 710 A12 4,400 7,500 A13 1,300 890 A14 1,065 700 A15 3,000 3,500 A16 1,300 1,700 A17 2,300 2,800 A18 5,200 1,500 A19 1,200 2,600 A20 2,034 2,500 A21 1,500 9,000 A22 700 522 Description Erosion/ near exposed piping Erosion/soil discoloration, multiple exceedances throughout area Erosion/exposed waste Well 258 at penetration and nearby exposed waste GW-261 at penetration and nearby erosion Exposed tire Soil crack Cover integrity issues, general area of exceedances GW189 multiple points on penetration Exposed waste, erosion gully, discolored soils erosion gulley GW187A multiple penetration points Soil crack, elevated throughout slope area of wide exceedance GW253 GW108B Exposed waste, erosion gully, discolored soils GW283 multiple penetrations at well erosion gulley and nearby discolored soil exposed waste GW282A Erosion gully Latitude Longitude 29.08596897 -95.35715885 29.08586231 -95.35697572 29.08566135 -95.35663178 29.08594017 -95.35633526 29.08633178 -95.35602616 29.08651285 -95.35606345 29.08638697 -95.35594851 29.08700568 -95.35614136 29.08708094 -95.35623312 29.08704893 -95.35615505 29.08713046 -95.35611623 29.08739283 -95.35634281 29.08729546 -95.35616215 29.08742963 -95.35621747 29.08762011 -95.35657209 29.08791663 -95.3565625 29.08788219 -95.35669983 29.08818841 -95.35653674 29.08815917 -95.35673282 29.08853755 -95.3564061 29.08857715 -95.35642404 29.08881124 -95.35654069 Page 10 of 14 Flag EPA Contractor Description Latitude Longitude Reading Reading A23 Erosion gulley and discolored soils, 29.08895845 -95.35657368 600 510 throughout area A24 erosion gulley 29.08888577 -95.35639775 920 1,100 A25 GW284 at wellhead and nearby exposed 29.08885551 -95.35621155 3,300 3,400 waste A26 GW176A at penetration 29.08825782 -95.35611835 4,300 6,500 A27 GW195A multiple penetration points 29.08790811 -95.35595525 1,500 3,300 A28 GW144B at post and multiple wellhead 29.0876845 -95.35604908 6,600 89,000 penetration points A29 exposed waste (recent construction) 29.08700032 -95.3558506 3,900 4,600 A30 GW170A (multiple penetrations) 29.08660579 -95.35555762 820 960 A31 GW165A penetration 29.08615326 -95.35560546 6,900 9,400 A32 Capped well GW264A (construction) 29.08586545 -95.35582748 6,100 9,600 A33 GW264 (multiple penetrations) 29.0858023 -95.35579962 1,400 2,000 A34 GW141B 29.08581022 -95.35525543 690 9,600 A35 GW268, surrounding exposed waste 29.08606924 -95.35521492 2,000 3,200 A36 GW-268A 29.08611151 -95.35528983 5,100 9,400 A37 Erosion gulley plus discolored soil 29.08513551 -95.35487794 800 560 A38 29.08494782 -95.35509369 1,300 530 A39 GW267 29.08503241 -95.35566328 1,200 1,600 B1 13,000 3,865 Leachate riser 4, at cap/cover 29.08605082 -95.35752441 B2 Surface near above ground piping 29.08614032 -95.3569641 1,175 1,800 B3 Surface rut/erosion 29.08613558 -95.3570005 1,595 803 B4 Two detects near surface erosion 29.08669703 -95.35686105 4,400 4,250 B5 Gas well 101, leachate noted coming up 29.0868934 -95.35695642 982 1,080 from ground nearby B6 Surface 29.08745165 -95.35758924 750 587 B7 42,500 38,000 Flameout, leachate riser 6, highest near 29.08777034 -95.35791614 where pipe ends Page 11 of 14 Flag EPA Contractor Description Latitude Longitude Reading Reading B8 Behind leachate riser 7 29.08800584 -95.35804211 640 585 B9 249 or 243 Toe Drain or leachate sump 29.08828498 -95.35724991 6,259 9,040 B10 Surface rut erosion 29.08844683 -95.35736335 1,410 2,760 B11 Gas well 237 from vacuum header 29.08873415 -95.35709778 6,690 16,000 B12 Gas well 111B 29.08908235 -95.35696502 1,150 1,050 B13 Gas well 178A 29.08938684 -95.35679304 4,470 3,255 B14 Gas well 285 29.08925616 -95.35624977 6,600 3,360 B15 Gas well 281 29.08849319 -95.35580616 2,883 3,100 B16 Gas well 254 29.08717067 -95.35509004 2,575 4,280 B17 Gas well 278 (exposed waste in area) 29.08675008 -95.35488648 1,160 1,285 B18 Gas well 278A 29.08672 -95.35496997 4,950 3,000 B19 Gas well 275A 29.08648808 -95.355185 6,594 45,000 B20 Gas well 164A 29.08638387 -95.35471721 1,220 1,495 B21 Gas well GW274 29.08607712 -95.35464607 1,083 545 B22 25,000 37,000 Gas well 140B, recently installed 29.08552714 -95.35465382 Background readings (taken by SCS): Upwind: 2.3 ppm Downwind: 2.4 ppm EPA readings were taken with three ThermoFisher Toxic Vapor Analyzer Flame Ionization Devices, calibrated using zero air and methane-in-air at 500, 2000, and 10,000 ppm. SCS/Contractor readings were taken with SEM5000s. Page 12 of 14 Facility Overview Map EPA annotations over Google Earth imagery dated 4/26/2022. Image is ~1.7 miles wide with north oriented up. Page 13 of 14 Map of Detected Exceedances Zoom in on map of EPA survey paths and detected exceedances, paths colored for each survey team. Yellow line is 100m for scale. Page 14 of 14