Document DG3NOwdr4E0eox8rR57XL1rxB
ELECTRONIC MAIL CONFIRMATION OF EMAIL RECEIPT REQUESTED
Brady Stewart Regional Engineer Anderson Regional Landfill 13146 Ballantyne Corporate Pl, Suite 150 Charlotte, North Carolina 28277 brady.stewart@wasteconnections.com
Dear Brady Stewart:
Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, North Air Enforcement Section, for the inspection conducted at Anderson Regional Landfill, located in Belton, South Carolina, on June 5, 2024.
If you have any questions, please contact me at 404-562-8134, or by email at Zhong.Baichen@epa.gov.
Sincerely,
Digitally signed by BAICHEN
BAICHEN ZHONG ZHONG
Date: 2024.08.14 11:24:24 -04'00'
Baichen Zhong Environmental Engineer North Air Enforcement Section
cc: Michael D Shroup Director, Compliance Management Division South Carolina Department of Environmental Services Michael.Shroup@des.sc.gov
United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch
FINAL INSPECTION REPORT
I. GENERAL INFORMATION Facility Name: Anderson Regional Landfill
Location (Address): 203 Landfill Rd., Belton, SC 29627
Inspection Dates: June 5, 2024
Type of Inspection (Full or Partial Compliance Evaluation): Clean Air Act Partial Compliance Evaluation
ICIS-Air Number: SC00002000149
EPA Investigator(s)/Inspector(s):
Baichen Zhong - Environmental Engineer Andrew Mills - Environmental Engineer Daniel Slade - Environmental Engineer Justin Stark - Physical Scientist Sarah Rowell - Environmental Engineer
State/Local Investigator(s)/Inspector(s): N/A
Person(s) Contacted at Facility (Name and Title):
Dustin Towne, Site Manager, Brady Stewart, Region Engineer, Waste Connections
Report Prepared by:
Baichen Zhong
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 1 of 19
II. FACILITY INFORMATION A. Facility and Permit Information
Facility and Permit Information
Comments
1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.).
2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.).
3. Air permit issuance date.
Municipal Solid Waste Landfill Title V permit GTV-0200-0149 November 1, 2021
4. Air permit expiration date.
October 31, 2026
5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor).
6. Major source pollutants (if applicable).
7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.).
8. Types of air emission points (e.g., tanks, process vents, boilers, etc.).
9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.).
Major Source
HAPs 40 C.F.R. Part 62, Subpart OOO 40 C.F.R. Part 63, Subpart AAAA
Gas collection and control system (GCCS), landfill surface emissions. Single Flare
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 2 of 19
B. Process Description (provide narrative or attach description provided by the company or excerpts from the permit)
The Anderson Regional Landfill receives municipal and industrial solid waste. The waste is deposited into the landfill, compacted, and covered with fill dirt or other suitable cover, on a daily basis. Landfill gas (LFG) is produced from the decomposition of the buried waste. It is composed primarily of methane and carbon dioxide and contains a small percentage of non-methane organic compounds (NMOC). The landfill operates a single flare for the control of landfill gas.
III. INSPECTION ACTIVITIES
Activity
Yes
No
NA
Opening Meeting
1. Date and time Y
entered the
facility.
2. Credentials Y
presented to
facility
personnel
(include name
and title).
3. Conducted an Y
opening
meeting to
explain the
purpose and
objectives of
the
inspection.
4. Discussed
Y
safety issues.
Comments
June 5, 2024, at approximately 9:10 a.m.
The EPA inspectors presented their credentials to Dustin Towne (Site Manager).
An opening meeting was held in the parking lot during which EPA explained that the Agency would be conducting an inspection under the Clean Air Act and that monitoring for methane emissions from the facility would be conducted.
The EPA inspectors wore the appropriate PPE as well as the standard yellow vest required by the facility. The EPA inspectors were accompanied by the facility staff listed above while walking and driving around the facility.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 3 of 19
Activity
Yes
No
NA
5. Discussed
Y
which records
to be
reviewed.
6. Discussed the Y
facility walk-
through and
the areas to
be observed
in the facility.
7. Discussed
Y
facility policy
regarding
photographs
or video (if
applicable).
8. Discussed the Y use of the infrared camera, TVA, PID, and any other equipment.
9. Discussed CBI. Y
Records Reviewed at the
Facility
See item 10
Comments
The EPA inspectors explained that the purpose of the inspection was to conduct a walk-through of the facility and to sample methane emissions at the landfill to assess the effectiveness of the landfill GCCS.
EPA inspectors indicated that videos may be taken with the infrared camera. If a video was taken, EPA would give the facility prior notice of the recording and ask that the facility identify any proprietary/CBI concerns before any video was taken to help EPA assess the need for the video. All videos taken during the inspection would be sent to the facility. Discussed the use of a FLIR camera, an Inficon IRwin infrared methane monitor device (IRwin), and a TVA.
The EPA inspectors indicated that any documents claimed to be Confidential Business Information (CBI) would be treated in accordance with the regulations.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 4 of 19
Activity
Yes
No
NA
10. The types of N
records
reviewed and
the time
period
reviewed.
Facility Walk-
Through
Observations
11. The process
Y
equipment
observed and
the associated
operational rate
observed (e.g.,
Furnace 1
production rate
was 5 lbs/hr on
1/1/15, at 2:00
pm - permit
requires max
rate at 6 lbs/hr).
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Comments
Records were not reviewed at the facility. EPA will send a 114 letter to discuss any documents or records that are needed.
Observations made during the inspection are recorded in Attachment A of this report. Descriptions of photographs and videos taken during the inspection are recorded in Attachment B of this report.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 5 of 19
12. The type of N/A process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch).
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 6 of 19
Activity
Yes
No
NA
13. If process
N/A
equipment or
parametric
monitoring
equipment
was not
operating,
state the
reason by
facility
personnel
why the
equipment
was not
operating.
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 7 of 19
14. The type of air Y pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.).
(For example RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher).
Provide the date and time the information was recorded
Waste gas generated from the decomposition of waste in the landfill is collected by a GCCS. The waste gas is sent to a flare for destruction.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 8 of 19
Activity
Yes
No
NA
by the
inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 9 of 19
Activity
15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.).
Yes No NA N/A
Provide the date and time the information was recorded by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 10 of 19
Activity
Yes
No
NA
16. If air pollution N/A
control
equipment
was not
operating,
state the
reason by
facility
personnel
why the
equipment
was not
operating.
17. Capture and Y collection system (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood).
Comments
Waste gas generated from the decomposition of waste in the landfill is collected by a GCCS. During the inspection, there were recorded instances of methane emissions above the leak definition of 500 ppm using the IRwin and confirmed by the TVA, as well as seen with the infrared camera. See Attachments B and C.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 11 of 19
Activity
Yes
No
NA
18. Ductwork
N/A
transferring
the emissions
to the air
pollution
control device
observations,
if applicable
(e.g., the
magnitude
and duration
of emission
escaping from
the ductwork,
holes or
deterioration
in ductwork,
no
deterioration
observed,
etc.).
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 12 of 19
Activity
19. Any existing unpermitted emission points, new unpermitted emission points, or nonpermitted construction activities observed. (if yes, describe in the comments field).
20. Were any visible emissions observed? (if yes, identify the location and equipment).
Yes No NA N/A
N
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 13 of 19
Activity
Yes
No
NA
21. Was a
N
Method 9
reading
performed? (if
yes, identify
the location
and
equipment).
22. Was the cause N/A of the visible emissions investigated and the information documented?
23. Was a
N
Method 22
performed for
visible
emissions? (if
yes, identify
the location
and
equipment).
Comments
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 14 of 19
Activity
24. Identify the cause of the visible emissions as explained by facility personnel, if applicable.
Yes No NA N/A
25. Was the
Y
infrared
camera used?
If so, attach
the video log
(which
includes the
equipment ID,
and the date
and time the
video was
recorded) and
videos to this
report.
Comments See Attachment B for a list of video files.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 15 of 19
Activity
Yes
No
NA
26. Was the TVA Y
used? If so,
identify the
equipment
monitored
and the
results.
Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release.
An attachment may be used for a large amount of information.
Comments
Two Inficon IRwin IR monitor was used to quantify methane concentrations near the surface of the landfill. See Attachment C for a description/schematic of the results/readings greater than the leak definition of 500 ppm.
Two TVAs were used for confirmation readings to confirm IRwin readings of methane concentrations near the surface of the landfill that exceeded 500 ppm.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 16 of 19
Activity
Yes
No
NA
27. Was the PID N
used? If so,
identify how
the PID was
used and the
results.
Provide the date and time the information was recorded by the inspector.
An attachment may be used for a large amount of information.
Comments
Closing Meeting 28. Conducted a Y
closing meeting.
29. Summarize Y any additional information needed, if applicable?
EPA Region 4 inspectors conducted a brief closing meeting on June 5, 2024, at around 3:47 PM with the facility personnel to discuss what occurred during the inspection and what will happen going forward. EPA will send a 114 letter, to request any documents or records that are needed.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 17 of 19
Activity
Yes
No
NA
30. Accept a
N/A
declaration of
CBI, if
applicable?
31. Discussed
Y
observations.
32. Discussed
Y
next steps, if
applicable?
33. Date and time Y inspection concluded.
Miscellaneous 34. Include any N/A
additional observations, if applicable.
Comments
EPA inspectors discussed the observations made during the inspection. This included the specific areas of elevated IRwin and TVA readings, and/or infrared video recordings at the extraction well sites, leachate collection and clean out areas, and the emissions recorded along the surface of the landfill cover. Condition of the landfill's cover integrity and issues observed with erosion and exposed waste were also discussed. The EPA inspectors stated that an inspection report and the submission of all recorded videos and pictures would be the next step in the process. A follow-up conference was scheduled to discuss any documents or records that are needed. June 5, 2024, 4:30 p.m.
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 18 of 19
EPA Investigator/Inspector Signature: EPA Supervisor Signature & Title
Digitally signed by BAICHEN
BAICHEN ZHONG ZHONG
Date: 2024.08.14 11:25:01 -04'00'
___________________________________
Digitally signed by JASON
JASON DRESSLER DRESSLER
____________________D_a_te_: _20_2_4._08_.1_4_1_1:_38_:1_6_-04'00' Chief, North Air Enforcement Section
Project Name: Anderson Regional Landfill Belton, SC ICIS/Project No.: SC00002000149
Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 6, 2019
Page 19 of 19
Attachment A - Inspection Activities and Observations
Opening Meeting, June 5, 2024
The inspection team arrived at the facility at around 9:10 AM and proceeded to conduct a brief opening meeting with Dustin Towne, the Site Manager after equipment calibration was done around 9:30 AM. EPA explained that the Agency would be conducting an inspection under the Clean Air Act and that monitoring for methane emissions from the facility would be conducted. A brief overview of the equipment used (IRwin, TVA, FLIR camera) was provided, and it was explained that the inspection team will primarily be conducting Surface Emission Monitoring (SEM) over the landfill.
Facility "Walk Through" and Surface Methane Monitoring
The inspection team set out in vehicles to view the facility. The team followed facility personnel, who rode in a separate vehicle, to the top of the landfill where the team disembarked and proceeded to conduct the SEM. Calibration for the IRwin and TVA was performed upon arrival at the facility. The inspection team split up into two groups to cover as much ground as possible, each with one IRwin and one TVA. Sarah Rowell used an IRwin to take measurements with Daniel Slade using a TVA for confirmation readings in the first group, while Justin Stark used an IRwin with Andrew Mills using the TVA in the second group. Baichen Zhong followed the first group with the FLIR camera to take images and videos of the landfill.
The results of the surface monitoring can be seen on Attachment C. Surface monitoring activities were focused primarily on penetrations of the landfill cap, including gas collection wells and other penetrations like risers. The air intake for the sampling device was attached to an extender probe, so that it would sample gas approximately 3 inches (7.5 cm) above the surface of the landfill. The probe was positioned along the circumference of each penetration monitored at several locations and allowed to stand at least 10 seconds which is twice the response time of the instrument. The maximum reading was then recorded along with the location of each reading. Overall, a large amount of surface emissions was detected, and the amount detected was a lot higher than what the facility had reported on their SEM reports. The inspection team witnessed large areas of poor cover integrity and exposed waste. Large gullies and other surface erosions were also seen, and images of them can be found on Attachment B. In addition, much of the slopes of the landfill are covered in dense vegetation, making traversal through the area difficult. The facility mentioned that from the second quarter onward, Sniffer Robotics will be contracted to perform SEM using drones instead of Oasis which is their former SEM contractor.
Closing Meeting
Following the conclusion of surface monitoring, a brief closing meeting was held in the parking lot with facility representatives Dustin Towne (Site Manager) and Brady Stewart (Region Engineer). It was explained that it is not EPA's policy to make definitive compliance determinations during an
inspection. However, EPA did voice concerns that, based on sampling results showing numerous locations where methane was detected at concentrations above 500 ppm, the landfill GCCS may be functioning poorly. Additional concerns regarding cover integrity and surface erosion were also voiced. EPA discussed the next steps, including that the facility would receive a draft inspection report in order to conduct a review for potential CBI. In addition, the facility was informed that a follow-up 114 letter would be sent to request any records or answers EPA might require. The inspection was concluded at approximately 4:30 p.m. on June 5, 2024.
Attachment B - Video and Photo Log
Img File Name
Date
Time Description
#
P1 DC_0110
6/5/2024 10:44 Poor cover integrity and exposed
waste (western slope)
P2 DC_0111
6/5/2024 10:50 Poor cover integrity and exposed
waste (western slope)
P3 DC_0112
6/5/2024 10:51 Poor cover integrity and exposed
waste (western slope)
P4 DC_0113
6/5/2024 10:52 Poor cover integrity and exposed
waste (western slope)
P5 DC_0116
6/5/2024 ~11:15 Area of erosion and leachate filled
gulley (western slope)
P6 DC_0118
6/5/2024 11:29 Large area of erosion/gulley (western
slope)
P7 DC_0119
6/5/2024 13:33 Riser #4
P8 DC_0121
6/5/2024 13:55 Exposed waste (eastern Slope)
P9 DC_0122
6/5/2024 14:00 Surveying pole between Wells 702 and
504R (Over 10% methane)
P10 DC_0124
6/5/2024 ~14:15 Well 402
P11 DC_0126
6/5/2024 ~14:10 Exposed waste (eastern Slope)
P12 DC_0127
6/5/2024 ~14:15 Large area of erosion/gulley (eastern
slope)
P13 WIN_20240605_10_43_37 6/5/2024 10:43 Extraction Well
P14 WIN_20240605_10_47_05 6/5/2024 10:47 Area of distressed vegetation
P15 WIN_20240605_10_51_14 6/5/2024 10:51 Exposed waste
P16 WIN_20240605_10_54_03 6/5/2024 10:54 Exposed waste
P17 WIN_20240605_10_54_06 6/5/2024 10:54 Exposed waste
P18 WIN_20240605_11_02_27 6/5/2024 11:02 Well 153
P19 WIN_20240605_11_02_43 6/5/2024 11:02 Exposed waste
P20 WIN_20240605_11_02_54 6/5/2024 11:02 Exposed waste
P21 WIN_20240605_11_02_58 6/5/2024 11:02 Exposed waste
P22 WIN_20240605_11_05_42 6/5/2024 11:05 Exposed waste
P23 WIN_20240605_11_05_48 6/5/2024 11:05 Exposed waste
P24 WIN_20240605_11_09_55 6/5/2024 11:09 Well 114R
P25 WIN_20240605_11_13_55 6/5/2024 11:13 Exposed waste
P26 WIN_20240605_11_18_33 6/5/2024 11:18 Capped penetration with flag
P27 WIN_20240605_11_21_18 6/5/2024 11:21 Extraction Well
P28 WIN_20240605_11_25_57 6/5/2024 11:25 Well 154R
P29 WIN_20240605_11_28_33 P30 WIN_20240605_13_41_06 P31 WIN_20240605_13_44_03 P32 WIN_20240605_13_50_28 P33 WIN_20240605_13_56_10 P34 WIN_20240605_13_56_40 P35 WIN_20240605_14_01_16 P36 WIN_20240605_14_05_35 P37 WIN_20240605_14_09_10 P38 WIN_20240605_14_14_12 P39 WIN_20240605_14_16_27 P40 WIN_20240605_14_20_42 P41 WIN_20240605_14_27_39 P42 WIN_20240605_14_27_56 P43 WIN_20240605_14_28_38 P44 WIN_20240605_14_28_48 P45 WIN_20240605_14_32_58 P46 WIN_20240605_14_38_04 P47 WIN_20240605_14_45_32 P48 WIN_20240605_14_50_40 P49 WIN_20240605_15_27_12 V1 MOV_0114 V2 MOV_0115
V3 MOV_0117
V5 MOV_0120 V6 MOV_0123
V7 MOV_0125 V8 WIN_20240605_13_41_17
6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024 6/5/2024
6/5/2024
6/5/2024 6/5/2024
6/5/2024 6/5/2024
11:28 13:41 13:44 13:50 13:56 13:56 14:01 14:05 14:09 14:14 14:16 14:20 14:27 14:27 14:28 14:28 14:32 14:38 14:45 14:50 15:27 11:00 11:03
11:21
13:50 14:00
14:08 13:41
Exposed waste Well 701 Well 701 Extraction Well Tarp cover Opened Extraction Well Closed Extraction Well Extraction Well Extraction Well Tarp cover Area of erosion Well 115R Large cavernous erosion from side Large cavernous erosion Area of erosion Area of erosion Area of erosion Well 602R Extraction Well Area of erosion Extraction Well Landfill gas bubbling up Poor cover integrity and exposed waste Unnamed well with orange flag (western slope) Surveying pole north of Well 702 Surveying pole between Wells 702 and 504R (Over 10% methane) Well 402 Well 701
Attachment C - IRwin Recorded Readings Log
Table 1: IRwin 1 Recorded Readings Log
ID
Reading
Description
(ppmv)
1
842
SSW of 1st well
2
3461
EW160. TVA Y
3
4056
NE of EW160
4
1103
NE of EW601. TVA Y
5
589
NE of EW601. TVA Y
6
55474
Ew153. TVA Y
7
982
Ew114r. TVA Y
8
7997
9
1464
Capped well NE of EW301f. TVA Y EW164r2. TVA Y
10
1434
EW154r2. TVA Y
11
1876
Auto fluff cover. TVA Y
12
10828
EW701. TVA Y
13
15600
EW201b. TVA Y
14
0
60mm cover. TVA Y
15
100832
EW501r
16
86050
EW300. TVA Y
17
5358
EW155r. TVA Y
LAT
LON
Timestamp
34.57836 34.57859 34.57865 34.579 34.57909 34.57973 34.57975 34.58024 34.58042 34.58052 34.58034 34.58154 34.58075 34.57995 34.57992 34.57927 34.57918
-82.4577 -82.4575 -82.4574 -82.4573 -82.4571 -82.4571 -82.4563 -82.4558 -82.4555 -82.4559 -82.4562 -82.4546 -82.4552 -82.4556 -82.4554 -82.4557 -82.4559
6/5/2024 10:35 6/5/2024 10:41 6/5/2024 10:45 6/5/2024 10:49 6/5/2024 10:52 6/5/2024 11:01 6/5/2024 11:08 6/5/2024 11:15 6/5/2024 11:20 6/5/2024 11:24 6/5/2024 11:28 6/5/2024 13:38 6/5/2024 13:49 6/5/2024 13:54 6/5/2024 13:58 6/5/2024 14:04 6/5/2024 14:07
18
866
19
971
20
7402
21
1257
22
5298
23
18992
24
3150
25
1283
Slip and slide cover. TVA Y By slip and slide. TVA Y EW115r. TVA Y Top of open hole inlf. EW602r. TVA Y EW707. TVA Y EW602.cell3e. TVA Y EW053.
34.57904 34.57891 34.5785 34.57893 34.57849 34.57788 34.5785 34.57514
-82.4559 -82.4559 -82.4557 -82.4554 -82.4551 -82.4548 -82.4548 -82.4592
6/5/2024 14:12 6/5/2024 14:15 6/5/2024 14:19 6/5/2024 14:32 6/5/2024 14:37 6/5/2024 14:43 6/5/2024 14:49 6/5/2024 15:26
Table 2: IRwin 2 Recorded Readings Log
ID Reading Description
(ppmv)
1
615
West of road S of well TVA Y
2
871
EW112 well TVA Y
3
1130
Rutt SE of well EW112 TVA Y
4
1146
NW of EW112 TVA Y
5
5256
W of EW507 TVA Y
6
3156
Well bottom of W face-unnamed with
orange flag TVA Y
7
556
NW of unnamed well TVA Y
8
3098
Riser 4 TVAY
9
2706
Clean out riser 4 TVAY
10 1318
SE Of riser 4 erosion TVA Y
LAT
LON
Timestamp
34.57837 -82.4577
34.57875 -82.4581
N/A
N/A
34.57909 -82.4581
34.57906 -82.4586
34.57868 -82.4593
34.57876 -82.4594
34.58243 -82.4547
34.58243 -82.4546
34.58213 -82.4548
6/5/2024 10:38 6/5/2024 10:44 6/5/2024 10:47 6/5/2024 10:53 6/5/2024 11:09 6/5/2024 11:25 6/5/2024 11:27 6/5/2024 13:34 6/5/2024 13:36 6/5/2024 13:42
11 1378
Pipe in ground SE Riser 4 TVA Y
34.58208 -82.4548 6/5/2024
13:44
12 2597
E of 506R erosion TVA Y
34.58111 -82.4546 6/5/2024
13:51
13 9522
Survey pipe next to 702
34.58099 -82.4546 6/5/2024
13:52
14 4645
Well 702 TVA Y
34.58077 -82.4546 6/5/2024
13:57
15 107230 Survey pipe between 504R and 702 TVA 34.58072 -82.4548 6/5/2024
Y
14:00
16 829
Erosion E of 504R TVA Y
34.58062 -82.455 6/5/2024
14:06
17 27186 402 TVA Y ALL penetrations detect
34.5803 -82.4549 6/5/2024
14:12
18 1114
Well 703 TVA Y
34.58008 -82.4546 6/5/2024
14:18
19 1020
Erosion S of 703
34.57984 -82.4546 6/5/2024
14:21
20 10650 Survey pipe S of 702
34.57966 -82.4546 6/5/2024
14:22
21 1545
Vacuum riser of 504R previous 504R
34.57963 -82.4547 6/5/2024
detects are 506R TVA Y
14:27
22 2670
SW of 704R TVA Y
34.57922 -82.4548 6/5/2024
14:30
23 2193
503R TVA Y
34.57915 -82.4552 6/5/2024
14:33
24 1311
Gully rutt erosion S of 503R TVA Y
N/A
N/A
6/5/2024
14:36
25 1681
Erosion W of 705 TVA Y
34.5787 -82.4549 6/5/2024
14:39
26 1251
EW 705 all penetrations TVA Y
34.57862 -82.4546 6/5/2024
14:42
27 2583
EW 47 both penetrations TVAY
34.57661 -82.4585 6/5/2024
15:27
28 15636 EW 050 flamed out TVA Y
34.57612 -82.4588 6/5/2024
15:31
29 793
NE of flag pole SE of EW 050 TVA Y
34.57593 -82.4585 6/5/2024
15:35
Attachment D - Instrument & Calibration Data
The survey was conducted using two Inficon IRwin devices using the Elkins Earthworks software. They are referred to throughout this report as the "IRwin 1" and the "IRwin 2"
Instrument Information
Instrument Type
IRwin 1
Inficon IRwin
IRwin 2
Inficon IRwin
Formal Identifier SK8185 B10406
Calibration Checks
Date/Time 2024-06-05 09:18 AM 2024-06-05 01:05 PM 2024-06-05 04:03 PM
Gas Concentration (ppm) IRwin 1 Reading (ppm)
500
500
500
520
500
460
IRwin 2 Reading (ppm) 500
503
490
Both instruments were calibrated according to Method 21 and manufacturer instructions with zero gas and 500 ppm methane. Bump checks were conducted before survey, midday, and after the survey.
Pre-survey bump checks show successful calibration. Midday bump check shows slight upward drift potentially resulting in false positives. Post-survey bump check shows downward drift, possibly resulting in false negatives (i.e., missed exceedances) and potential underestimation of the severity of measured exceedances.
Calibration Gas Composition
Zero air <1 ppm total hydrocarbon 500 ppm methane in air
Calibration Gas Supplier Pine Environmental
Pine Environmental
Lot Number 304-401830967-1 304-401851836-1
Expiration Date 09/03/2024 07/10/2024
Response Time and Precision Check
IRwin 1
Trial
Calibration Gas ppm Reading (ppm)
1
500
500
2
500
500
3
500
500
Time (s) 5 5 4
IRwin 2 Reading (ppm) 500 500 500
Time (s) 5 4 5
Both instruments were calibrated and checked for response time and precision on 06/05/24 at 9:18 am using the 0 air and 500 ppm from the same cylinders as during the inspection. All readings are within 10% of the known calibration value. Response times are approximately 4-5 seconds, under the maximum of 30 seconds.
TVA Instrument & Calibration Data
Two Toxic Vapor Analyzer (TVA) were used for confirmation readings of the readings done by the IRwin devices. They are referred to throughout this report as the "TVA 1" and the "TVA 2". Readings for TVA were not recorded as they were used to confirm IRwin readings above 500 ppm.
Instrument Information
Instrument Type
TVA-1
TVA
TVA-2
TVA
Formal Identifier B10208 B10376
Calibration Log TVA-1 Initial Accuracy Test Expected Reading (ppmv) Span Reading Calibration/Concentration Check Calibration Gas Supplier
Calibration Gas Expiration Bump Check Date/Time: N/A
Zero 3025
500 140472 500
1000 306784 1057
10000 2756864 9800
Pine
Pine
Pine
Pine
Environmental Environmental Environmental Environmental
9/3/2024
7/10/2024
12/2/2026
12/2/2026
N/A
N/A
N/A
N/A
TVA-2 Initial Accuracy Test Expected Reading (ppmv) Span Reading Calibration/Concentration Check Calibration Gas Supplier
Calibration Gas Expiration Bump Check Date/Time: 06/05/2024, 4:03PM
Zero 4285
500 146936 490
1000 319776 990
10000 2848256 9900
Pine
Pine
Pine
Pine
Environmental Environmental Environmental Environmental
9/3/2024
7/10/2024
12/2/2026
12/2/2026
489
1023
10800
Both instruments were calibrated according to Method 21 with zero gas, 500 ppm methane, 1,000 ppm methane, and 10,000 ppm methane. Bump check was conducted after the survey for TVA-2. TVA-1 suffered flameout due to lack of hydrogen and wasn't bump checked after the survey.
Post-survey bump check for TVA-2 shows downward drift, possibly resulting in false negatives (i.e., missed exceedances) and potential underestimation of the severity of measured exceedances.
Calibration Gas Composition Zero air <1 ppm total hydrocarbon 500 ppm methane in air 1,000 ppm methane in air 10,000 ppm methane in air
Manufacturer Airgas Airgas Airgas Airgas
Lot Number 304-401830967-1 304-401851836-1 304-402606646-1 304-402606645-1
Expiration Date 09/03/2024 07/10/2024 12/02/2024 12/02/2024