Document DdB42O2Z1NNgeVO7609BanwJd

Participating Personnel: Report Prepared by: Approved by: Leak Detection and Repair (LDAR) Inspection Report Edgeboro Landfill (aka Cinnamon Bay LLC) 53 Edgeboro Rd, East Brunswick, NJ 08816 AIRS ID: NJ0000003402316340 Inspection Date(s): July 24, 2024 US Environmental Protection Agency Omer Sohail, PE, Environmental Engineer Phillip Ritz, Environmental Scientist Hannah Patel, Environmental Scientist OMER SOHAIL Digitally signed by OMER SOHAIL Date: 2024.09.19 13:27:04 -04'00' Omer Sohail, PE Environmental Engineer Monitoring and Assessment Branch CAROL LYNES Digitally signed by CAROL LYNES Date: 2024.09.20 11:17:30 -04'00' Carol Lynes, Manager Monitoring and Assessment Branch Page 2 of 4 LDAR Inspection of Edgeboro Landfill (aka Cinnamon Bay LLC), East Brunswick, NJ Table of Contents: Leak Detection and Repair Report 1-4 Introduction 3 Management System Review 3 Technical System Audit 3 Compliance Monitoring 4 Follow-Up 4 Appendices 1 Inspection Attendance Sheet LSASD/MAB/QATSS AIRS ID: NJ0000003402316340 Edgeboro Landfill East Brunswick, NJ Page 3 of 4 LDAR Inspection of Edgeboro Landfill (aka Cinnamon Bay LLC), East Brunswick, NJ Inspection Date: July 24, 2024 Introduction: The closed and capped Edgeboro Landfill is located near Edgeboro Road in East Brunswick, NJ. The closed and capped Edgeboro Landfill facility is regulated under the Federal Clean Air Act Title V Air Permit Facility ID 17901 ("Title V Permit") issued by the New Jersey Department of Environmental Protection ("NJDEP"). The Title V Permit covers the closed and capped Edgeboro Landfill as well as the nearby Power Plant facility. The Edgeboro Landfill operated from 1954 to 1993 and includes Section 1, Section 2, and Section 3. The landfill is adjacent to the Middlesex County landfill. Management System Review: Objective: A management system review consists of an evaluation of the facility's current LDAR program, which includes interviews with staff responsible for overseeing the program and any staff or contractors who perform routine monitoring and data management. Documents reviewed by EPA Region 2 inspectors (hereafter referred to as inspectors) include, but are not limited to previous reports, monitoring data, monitoring runs, component leak histories, leak repair procedures, calibration gas certificates of analysis, calibration logs, calibration precision testing, and calibration response time testing. Observations: Edgeboro Landfill's SEM contractor, Sadat Associates (Sadat) performs all surface emissions monitoring at Edgeboro Landfill Section 1, Section 2 and Section 3. Any instrument reading greater than 500 ppm is considered an exceedance. If an exceedance is found by Sadat, a GPS location is taken, the area is flagged, and William Stetson, Edgeboro Landfill Senior Project Manager, is notified. According to Sadat, re-monitoring is performed by Sadat within 10 days. If the area passes remonitoring, follow-up monitoring is performed in 30 days. If the area does not pass the recheck, another attempt at repair is made, and re-monitoring is performed within 10 days. Omer Sohail reviewed the Semi Annual NSPS and SSM reports from January 2023 to January 2024, which include all quarterly surface monitoring conducted during those periods. All reports were found to be satisfactory. Technical System Audit: LSASD/MAB/QATSS AIRS ID: NJ0000003402316340 Edgeboro Landfill East Brunswick, NJ Page 4 of 4 Objective: A Technical System Audit (TSA) consists of an audit of the instrumentation and calibration gases being used for routine LDAR monitoring. Calibration gases will be checked and the inspector will observe the facility LDAR technician or contractor performing a routine calibration. The procedure used to perform a calibration precision test and response time test will also be observed. This portion of the audit evaluates conformance to Method 21 of 40 CFR Part 60, Appendix A. Observations: Edgeboro Landfill surface monitoring contractor, Sadat, was present during EPA's inspection; however, did not bring any surface monitoring equipment with them. Therefore, there are no observations to report. Compliance Monitoring: Objective: Inspectors perform all compliance monitoring with the facility technician or contractor present to provide confirmation of any leaks detected by EPA. The inspection will consist of side-by-side monitoring where the inspector will monitor several components immediately after the facility technician or contractor has monitored the same component. This is done to verify monitoring technique, ability to find leaks, and performance of the facility's instrument. All monitoring data are summarized in Table 1 of this report. Observations: Side by side surface monitoring could not be conducted as Sadat did not bring the required equipment necessary for surface emission monitoring during EPA's inspection; however, EPA did continue the inspection. All results were relayed verbally in the field to Sadat's inspector Nick Morgan. Monitoring results are included in Table 1 of this report. Calibration of the TVA2020 was completed in the field prior to starting the surface emissions monitoring. The following calibration gasses were used in the daily calibration: Zero Air, Methane 505 ppm, Methane 1025 ppm, and Methane 1% volume. Background concentrations were determined both upwind and downwind of the landfill, with results included in Table 1. A total of 29 points were monitored over the two-day period. Any reading above 500 ppm is considered a leak (60.755(c)(4)). EPA detected 0 leaks, which equates to a leak rate of 0%. Region 2 inspectors used GIS Map Pro on iPhone 13 to record the coordinates of each point monitored at Edgeboro Landfill. Coordinates for each point monitored can be found in Table 1. Follow-Up: At the closing conference held on July 24, 2024, Omer Sohail reviewed all the findings of the inspection with Lahbib Chibani, President of Sadat Associates. No leaks were identified during the inspection; therefore, an exceedance table was not sent and follow up for repairs was not required. LSASD/MAB/QATSS AIRS ID: NJ0000003402316340 Edgeboro Landfill East Brunswick, NJ MCUA Landfill East Brunswick, NJ USEPA Inspection Attendance Sheet (July 22 - 23, 2024) Name Omer Sohail Hannah Patel Phil Ritz Lahbib Chibani Nick Morgan William Stetson Role/ Company Inspector, EPA, LSASD R2 Inspector, EPA, ACB R2 Inspector, EPA, ACB R2 President, Sadat Associates Scientist, Sadat Associates Senior Project Manger, Edgeboro Landfill Email Address sohail.omer@epa.gov patel.hannah@epa.gov ritz.phillip@epa.gov Attended Opening Conference Attended Closing Conference Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Edgeboro Landfill (aka Cinnamon Bay LLC) 53 Edgeboro Rd, East Brunswick, NJ 08816 Date of Inspection: July 24, 2024 Weather: July 24 - Mostly Sunny, High of 84 Sample ID Upwind Downwind CO-6 CO-7 EW-06 EW-08 HC-3 GW-03 HC-4 GC-5 EW-20 EX4M1B EW-27 EW-28 EW-30 EW-37 EW-40 GW-R7 EW-45 EW-47 GW-R GW-NA GW-R14 EW-9 PVC42M GW-N3 EW-82 EW-86 EW-92 Concentration (ppm) 1.0 2.1 1.4 1.3 1.2 3.6 1.2 1.7 1.5 1.6 1.5 1.6 1.7 1.8 0.4 1.9 1.9 1.9 2.0 2.1 2.2 2.3 2.3 8.7 17.1 8.4 1.7 0.4 6.1 Approximate GPS Location 40.4670 74.3857 40.4281 74.2360 40.2710 74.2220 40.2810 74.2313 40.2820 74.2330 40.2830 74.2330 40.2860 70.2310 40.2890 74.2310 40.2810 74.2310 40.2811 70.2310 40.2811 74.2300 40.2812 74.2328 40.2813 74.2260 40.2814 74.2259 40.2824 74.2258 40.2830 74.2255 40.2831 74.2255 40.2832 74.2254 40.2836 74.2255 40.2831 74.2211 40.2836 74.2260 40.2834 74.2257 40.2833 74.2255 40.2832 74.2326 40.2832 74.2326 40.2830 40.2827 40.2827 40.2823 74.2326 74.2330 74.2335 74.2330 Sample Location Ambient Ambient Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Repaired Notes Background concentration from MCUA Landfill ~25 ppm Page 1 of 1