Document G5eJGdd5pqGoebYzKvdEy9wjv

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 Republic Services McCarty Road Landfill, Houston, 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: Republic Services McCarty Road Landfill Facility Location: 5757 Oates Road, Houston, TX 77078 Date of Inspection: On Site Inspection: March 14, 2023 Virtual Conference: May 2, 2023 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist, EPA OECA a,b 2. Daniel Hoyt, Environmental Engineer, EPA OECA a,b 3. Colleen McCarthy, Life Scientist, EPA Region 6 b 4. Kenneth McPherson, Life Scientist, EPA Region 6 b 5. Benjamin Rosenthal, Air Inspector, EPA Region 6 a,b Other Attendees: 1. Nathanial Wells, Environmental Manager for McCarty Road, Republic Services a,b 2. Scott Trebus, Area Environmental Manager for the State of Texas, Republic Services a 3. Nikki Wuestenberg, Senior Manager Air Compliance, Republic Services a 4. Angie Vandergriff, Project Director, Weaver a 5. Matt Stutz, Senior Engineer, Weaver a 6. Joe Mosier, Landfill Manager for McCarty Road, Republic Services b 7. Tyler Tandy, Environmental Specialist for McCarty Road, Republic Services b 8. Kevin Vasquez, Operation Manager for McCarty Road, Republic Services b a Attended conference b Attended surface emissions monitoring (SEM) Page 1 of 14 Contact Email Address: nwells2@republicservices.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 WWW; 40 C.F.R. Part 62, Subpart OOO; 40 C.F.R. Part 63, Subpart AAAA; 40 C.F.R. Part 98, Subpart HH On Site (3/14) Arrival Time: 11:00 Central On Site (3/14) Departure Time: 16:30 Central Virtual Conference (5/2) Start Time: 14:00 Central Virtual Conference (5/2) End Time: 16:00 Central Inspection Type: Unannounced Inspection Announced Inspection SITE OVERVIEW The following information was obtained verbally from Republic Services representatives, including their consultants, during the virtual conference. Company Ownership: The McCarty Road Landfill ("the Landfill") is operated as McCarty Road Landfill TX, LP, which ultimately is owned by Republic Services. The Landfill previously was operated under BFI and then Allied Waste prior to their eventual merger with Republic. Operations Overview: The Landfill began operations around 1970, and currently has approximately 388 acres with waste in place, fully utilizing the permitted footprint. There is no further capacity for expansion and there is approximately 15 years remaining in capacity, pending market conditions. The Landfill accepts approximately 6,000 tons per day of waste. Waste includes MSW, construction and demolition (C&D) waste, class 2 non-hazardous industrial waste (plant trash), and contaminated soils. C&D waste from storms affects the year-to-year tonnage. The site does accept asbestos waste. The Landfill does deposit solidified liquids. Of the 388 acres, approximately 50 acres are post RCRA Subtitle D in the southeast of the site. Overliner has been installed on top of older pre-RCRA sections. Leachate in lined portions of the landfill goes from sumps to holding tanks. Disposal from the tanks is both trucked off site or directly sent to the Houston Publicly Owned Treatment Works, pending volumes. There is approximately 117 acres of final cover on some of the side slopes. Intermediate cover is 12" of soil, required to be put in place if not filling for 6 months in an area by their Solid Waste Page 2 of 14 Permit. Daily cover requires soils if in place for more than 24 hours. Alternative daily cover includes tarps, petroleum contaminated soils, and a half auto shredder fluff half soil blend. The gas collection and control system (GCCS) contains approximately 500 wells. These are primarily vertical wells. The entire landfill is subject to gas collection requirements. In active areas, Republic may add horizontals as they are filling and then add vertical wells when the area is done being filled for that period. Horizontals vary from 75 to 125' vertical spacing, and pending fill sequence 30-50'. Vertical wells are typically spaced 200' apart though this is variable. Wellhead spacing is decided by the design engineers, typically consultants from Weaver and SCS. Leachate risers can have vacuum pulled on them for gas collection, this is done on an "as needed" basis. All collected gas goes to a common header, and all gas collection is active. Typical collection is in the range of approximately 9000 to 9500 standard cubic feet per minute (scfm) normalized to 50% methane. Collected gas goes to a blower/flare system. Connections from the blower can discharge to two separate renewable natural gas (RNG) plants, and gas volumes beyond what the plants accept is flared off. There is typically an amount of gas being flared. The exact same gas is routed to the flares as two each of the plants. Ameresco operates one of the plants, and typically takes approximately 4500 scfm of gas. Montauk/GSF operates the other plant, and can take up to approximately 5500 scfm but more typically takes around 4500 scfm. There are two enclosed flares with 6000 scfm capacity each, and one candlestick with a 3000 scfm capacity. When the plants are operating, the candlestick usually handles the excess gas to accommodate so that the lower flows can still be adequately handled minding the turndown ratio for each flare. SITE TOUR -- MARCH 14, 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 facility representatives to identify any confidential business information (CBI) that was provided, observed, or discussed during the inspection. No CBI was identified. Data Collected and Observations: EPA conducted an abbreviated SEM survey of the facility. EPA used three ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020) to perform EPA Reference Method 21 for the SEM. EPA monitored in two teams, with the third instrument moving between the two teams to provide confirmation readings for each exceedance point. GPS tracks were recorded for the confirmation instrument. Ben Rosenthal and Daniel Hoyt took primary readings, with Dan Heins providing confirmations. EPA monitoring focused on part of the northern area of the Landfill, an area that had not seen any recent construction or waste deposition activity, covering an area of less than 40 acres. See Appendix C for maps. EPA inspectors identified 55 total points above 500 ppm methane. Only two points were not able to be confirmed. Page 3 of 14 While driving around the landfill to take upwind and downwind measurements, EPA noted an elevated area of methane. This was a widespread area of exceedance by ES-2, with exceedances at gaskets and from the base and top of nearby survey posts. In the main area of SEM survey on the northern portion of the Landfill, exceedances were found primarily at penetrations and areas of erosion/exposed waste. Photos and/or Videos: were taken during the inspection. See Appendix A. Field Measurements: were taken during this inspection. See Appendix B. INSPECTION CONFERENCE -- MAY 2, 2023 Provided U.S. EPA point of contact to the facility Asked the facility representatives to identify any CBI provided, observed, or discussed during the inspection. No CBI was identified. EPA showed facility representatives a map of the path walked during the on-site SEM survey and the exceedances detected. Staff Interview: The Landfill was previously operating under NSPS Subpart WWW until the Federal Plan Subpart OOO came into effect. The Landfill has a Design Capacity of greater than 2.5 million Mg and cubic meters, has an uncontrolled emission rate of NMOC of greater than 50 Mg, and has been subject to GCCS requirements for greater than five years. The Landfill checks perimeter probes quarterly for gas migration. There is an active soil vapor extraction system tied into the GCCS to control migration, primarily located on the north and east side of the landfill. Probes are located outside these extractors. Some gas wells have dewatering pumps, with the operations and maintenance contractors deciding when to add or remove the pumps. Liquid levels are checked quarterly. There are no defined action levels, pumps are added based on design engineer recommendations. The wellfield is manually tuned, with wells checked twice a month. All adjustments are logged. There are not specific contract limits on gas quality for the RNG plants. If either plant sees rising oxygen/nitrogen levels, they will call the landfill and the operations/maintenance contractors will try to find the source of the issue, which may be from weather, construction, or a need for rebalancing. Wells designated as "odor control wells" are the soil vapor extractors and gas collection on the leachate system; Republic was uncertain if any interior wells were labeled as such. Wells designated as "nonproducing" are from older areas with low gas production that Republic does not want to remove. They are still monitored monthly, but there is no synthetic liner or geomembrane. Page 4 of 14 Tetra Tech performs the SEM for the site, currently using an IRwin. Republic stated that they have the calibration information and should have the map of where the technicians walk. There is no list of all penetration points for monitoring, the technicians identify them while walking. Active operations and construction areas (including GCCS construction) are excluded as dangerous areas. Republic has not recently identified slopes as being too steep to monitor and has not excluded areas based on high vegetation. Corrective actions are typically done by the operations team but may be contracted. There is no formal log of corrective actions. Monthly cover integrity monitoring is performed in coordination with the wellfield operations/maintenance team. There are formal logs for this monitoring and corrective actions. The landfill does not currently have elevated temperature areas. There was a subsurface oxidation event from a localized airline break that was resolve approximately a year and a half ago. Collection shutdowns identified as "General Alarm" in their semiannual reports could be a pressure drop, electric issue, or high or low temperature alert from the flare. That is the general output from the monitoring program Republic uses. EPA asked if Republic was aware of Carbon Mapper flyover data for the facility. They stated that Carbon Mapper had flown the site recently and that Republic believed the plumes measured came from the active area. Republic stated that the delay in receiving data from the June 2022 flyover made it hard to identify potential cause and respond. Reviewed documents: Prior to inspection (available publicly online): October 2022 Semi-Annual Report, including 2022 Q2 & Q3 SEM results o Q2 SEM 68 exceedances total Fewer than 20 in the approximate area of EPA survey o Q3 SEM 60 exceedances total Fewer than 10 in the approximate area of EPA survey February 2022 Subpart OOO Initial Report, including 2021 Q3 SEM results o 2021 Q3 SEM 45 exceedances total Fewer than 5 in the approximate area of EPA survey Requested documents: After discussing preference between a Section 114 Request For Information Letter and an emailed list of documents associated with the inspection, Republic expressed a preference for the latter. Page 5 of 14 Concerns: EPA noted the disparity between the number of exceedances they had found compared with the reviewed recent SEM surveys, indicating possible concerns with the quality of the SEM surveys EPA noted that erosion and exposed waste was seen across the survey area EPA noted that some of the pneumatic pump outlets were venting landfill gas (and condensate), and that the carbon cannisters being utilized did not effectively control the emissions DIGITAL SIGNATURES _________________________________ Daniel Heins, Lead Inspector GREGORY Digitally signed by GREGORY FRIED FRIED Date: 2023.06.30 09:04:51 -04'00' __________________________________ Gregory Fried, Supervisor Page 6 of 14 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Field Measurement Appendix C: Maps Page 7 of 14 APPENDIX A: DIGITAL IMAGE LOG Inspector Name: Colleen McCarthy Archival Record Location: US EPA SharePoint Images (1 of 2) Image # File Name 1 IMG_4004.JPG 2 IMG_4006.JPG 3 IMG_4007.JPG 4 IMG_4008.JPG 5 IMG_4009.JPG 6 IMG_4010.JPG 7 IMG_4011.JPG 8 IMG_4012.JPG 9 IMG_4013.JPG 10 IMG_4014.JPG 11 IMG_4015.JPG 12 IMG_4016.JPG 13 IMG_4017.JPG 14 IMG_4018.JPG 15 IMG_4021.JPG 16 IMG_4022.JPG 17 IMG_4023.JPG 18 IMG_4024.JPG 19 IMG_4025.JPG 20 IMG_4026.JPG 21 IMG_4027.JPG 22 IMG_4028.JPG 23 IMG_4029.JPG 24 IMG_4030.JPG 25 IMG_4031.JPG 26 IMG_4032.JPG 27 IMG_4033.JPG Description A3 erosion gulley with exposed waste A2 penetration A4 EW295A A5 EW501 A6 Erosion with exposed waste A7 EW500 A8 Erosion gullies with exposed waste A9 EW427A A9 EW427A closeup on pneumatic leaking gas & condensate A10 Erosion/exposed waste A11 EW423 A12 LI423 Leachate breakout/distressed vegetation A13 Well A14 Erosion gullies with exposed waste A15 Erosion gullies with exposed waste A16 EW407 A17 LI378 A18 EW375A A19 Erosion with exposed waste A20 Erosion with exposed waste A21 EW374 A22 Bare earth/discolored soils A23 EW385 A24 EW383 A25 EW404 A26 EW410 Date/time (Central) 2023:03:14 12:34:58 2023:03:14 12:35:26 2023:03:14 12:38:23 2023:03:14 12:43:50 2023:03:14 12:45:44 2023:03:14 12:48:50 2023:03:14 12:51:19 2023:03:14 12:53:28 2023:03:14 12:53:35 2023:03:14 12:59:07 2023:03:14 13:01:02 2023:03:14 13:03:03 2023:03:14 13:05:37 2023:03:14 13:14:04 2023:03:14 13:16:41 2023:03:14 13:18:48 2023:03:14 13:28:20 2023:03:14 13:53:51 2023:03:14 13:57:12 2023:03:14 14:02:30 2023:03:14 14:06:50 2023:03:14 14:11:48 2023:03:14 14:18:42 2023:03:14 14:24:35 2023:03:14 14:36:24 2023:03:14 14:39:58 2023:03:14 14:47:34 Latitude 29.83149 29.83153 29.83471 29.83106 29.83122 29.83088 29.83083 29.83091 29.83089 29.83098 29.83095 29.83094 29.83114 29.83052 29.8305 29.83054 GPS Error 29.83151 29.8311 29.83142 29.8312 29.83107 29.83086 29.83062 29.83024 29.83024 29.83017 Longitude -95.235336 -95.235139 -95.235611 -95.235594 -95.235961 -95.236075 -95.236336 -95.236581 -95.23655 -95.236856 -95.237014 -95.237022 -95.237672 -95.238031 -95.238183 -95.238425 GPS Error -95.240662 -95.240953 -95.240914 -95.241212 -95.2415 -95.241775 -95.241714 -95.24105 -95.240334 -95.239731 Page 8 of 14 Images (2 of 2) Image # File Name 28 IMG_4034.JPG 29 IMG_4035.JPG 30 IMG_4037.JPG 31 IMG_4038.JPG Description A27 EW419A A28 EW424A with carbon can on pneumatic outlet A29 Erosion gulley 5cm spacer on instrument Date/time (Central) 2023:03:14 14:57:55 Latitude Longitude 29.8301 -95.238487 2023:03:14 15:08:00 2023:03:14 15:21:40 29.83041 -95.23735 29.8317 -95.236131 2023:03:14 17:57:47 NA NA Page 9 of 14 APPENDIX B: FIELD MEASUREMENT DATA Measured Exceedances (1 of 2) EPA EPA Reading Confirmation Flag (ppm / %) (ppm / %) A1 894 A2 910 A3 1100 A4 903 A5 650 A6 1622 A7 1138 A8 4600 2100 1900 640 1300 670 2000 1400 2500 A9 4838 2500 A10 827 760 A11 857 960 2.5% / Flame A12 2900 out A13 870 2200 A14 6900 2800 A15 2900 6900 A16 1100 900 A17 4200 3200 A18 5900 6200 A19 790 900 A20 1000 1050 A21 2500 1100 A22 819 730 A23 3790 2900 A24 1000 1100 A25 1200 1300 A26 1240 540 A27 2600 3500 A28 2300 750 Description/notes Multiple points throughout mound and well at penetration of riser erosion/exposed waste EW 295A at pipe EW-501 at leaking ball valve exposed waste in erosion gulley EW-500, base of well erosion/exposed waste EW-427A, pump pneumatic outlet leaking gas/condensate erosion/exposed waste EW 423 at base LI 423 uncapped at seal on wellhead erosion/exposed waste erosion/exposed waste EW-407 LI-378 at top of wellhead and at ground level. 1% & flame out at top. EW 375A erosion/exposed waste erosion/exposed waste EW 374 at pipe erosion EW385 (no flag) EW 383 (at base of mount and on top) EW 404 at base of well EW410 at penetration above cover, south side of well EW419A both at wellhead and lateral line EW424A base and pneumatic outlet (2.5% & flameout at outlet, still read over 1% at outlet of replaced carbon can) Latitude 29.831450 29.831516 29.831462 29.831358 29.831007 29.831185 29.830878 29.830801 29.830874 29.830907 29.830983 29.830977 29.830507 29.830517 29.830544 29.830955 29.831501 29.831100 29.831161 29.831174 29.831178 29.830867 29.830613 29.830253 29.830261 29.830178 29.830099 29.830431 Longitude -95.234580 -95.235137 -95.235343 -95.235387 -95.235600 -95.236006 -95.236069 -95.236365 -95.236563 -95.236880 -95.237058 -95.237086 -95.238071 -95.238188 -95.238424 -95.238371 -95.240688 -95.240992 -95.241118 -95.241228 -95.241641 -95.241731 -95.241738 -95.241018 -95.240268 -95.239706 -95.238462 -95.237328 Page 10 of 14 Measured Exceedances (2 of 2) EPA EPA Reading Confirmation Flag (ppm / %) (ppm / %) A29 1600 2600 B1 600 Unconfirmed Flameout B2 (>5%) NA B3 700 1100 B4 1020 1100 B5 1150 3400 B6 1090 571 B7 615 610 B8 655 700 B9 585 Unconfirmed B10 905 1200 B11 985 1100 B12 770 880 B13 720 1400 B14 610 822 B15 650 959 B16 1100 875 B17 1139 800 B18 6100 6600 B19 900 1300 B20 850 1500 B21 1350 970 B22 4800 5000 B23 650 850 B24 560 720 B25 600 1700 C1 5000 NA Description/notes Erosion gulley EW212A (Confirmation not attempted to avoid flame out) Already flagged "22" EW211A EW421 Already flagged "33" Bare soil Already flagged "38" Ground penetration Ground penetration Ground penetration Ground penetration Ground penetration Ground penetration Ground penetration EW338A Ground penetration EW373 EW436 EW372A EW384 EW438 EW382 Ground penetration EW413 ES-2 (by gaskets) and at bases and tops of nearby survey posts. (No confirmation reading attempted) Latitude 29.831664 29.831796 Longitude -95.236212 -95.234953 29.831742 29.831736 29.831803 29.831369 29.831380 29.831366 29.831290 29.831431 29.831433 29.831468 29.831338 29.831154 29.831467 29.831448 29.831377 29.831075 29.830958 29.830590 29.830482 29.830671 29.830461 29.830619 29.830416 29.830214 -95.235135 -95.235231 -95.235594 -95.235976 -95.236636 -95.237161 -95.238161 -95.238618 -95.238964 -95.239502 -95.239663 -95.239913 -95.240520 -95.241400 -95.242170 -95.242254 -95.242168 -95.242091 -95.242304 -95.241206 -95.241112 -95.240640 -95.240218 -95.239095 29.822670 -95.235720 Page 11 of 14 Calibration and Instrument Information EPA used three ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020), numbered 202017092712, 202023016408, and 202016081525 (and designated as TVAs "Green", "Red" and "Black"). The EPA TVA2020 response times are approximately 4.5 seconds. EPA calibrated with 500 ppm methane in air, 10,000 ppm methane in air, and zero gas at the TCEQ Houston office prior to arrival on site. Morning Calibration Bump Checks TVA 500 ppm cal 10,000 ppm cal gas gas Black 485 ppm 9,620 ppm Red 481 ppm 10,500 ppm Green 493 ppm 9,900 ppm Upwind and downwind readings were less than 10 ppm. Page 12 of 14 APPENDIX C: MAPS Site Overview Map Blue line shows main EPA survey coverage, tracing the confirmation reading instrument. C1 marks the additional exceedance separately from main survey. Active area in central eastern portion of landfill at time of survey. Satellite imagery dated to April 2022 as shown on Google Earth. Page 13 of 14 Map of Detected Exceedances Blue line roughly shows EPA survey coverage, tracing the confirmation reading instrument. Exceedance locations labeled with their flag numbers. Yellow line is 100m, north is up. Satellite imagery dated to April 2022 as shown on Google Earth. Survey area covered less than 40 acres. 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