Document Qg3GeqR3pZNVqR9gK8ZKEg7Ro
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
ATLANTA FEDERAL CENTER 61 FORSYTH STREET S.W
ATLANTA, GEORGIA 30303-8960
SENT VIA ELECTRONIC MAIL
Mr. Patrick Dunson City Engineer, Engineering and Environmental Services, City of Montgomery North Montgomery Municipal Solid Waste Landfill 115 Division Street Montgomery, Alabama 36104 pdunson@montgomeryal.gov
Dear Mr. Dunson:
Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, South Air Enforcement Section, for the inspection conducted at the North Montgomery Municipal Solid Waste Landfill facility, located in Montgomery, Alabama, on March 15, 2022.
If you have any questions, you can contact me at (404) 562-9134, or by email at taylor.kevin@epa.gov.
Enclosure
Sincerely,
Taylor, Kevin
Digitally signed by Taylor, Kevin Date: 2022.05.24 10:58:54 -04'00'
Kevin Taylor Environmental Engineer South Air Enforcement Section
ENCLOSURE A INSPECTION REPORT
United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report
I. GENERAL INFORMATION Facility Name: North Montgomery Municipal Solid Waste Landfill
Location (Address):
115 Division Street Montgomery, Alabama 36104
Inspection Date:
March 15, 2022
Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation
ICIS-Air Number:
AL0000000110100078
EPA Investigator(s)/Inspector(s): 1. Kevin Taylor, Environmental Engineer 2. Sydnee Adams, Environmental Engineer 3. Andrew Mills, Environmental Engineer 4. Katelyn Bergl, Environmental Engineer
State/Local Investigator(s)/Inspector(s): 1. John Robert Gill, Environmental Engineer Alabama Department of Environmental Management (ADEM)
Person(s) Contacted at Facility (Name and Title): 1. Radonda May, Assistant Superintendent North Montgomery Landfill, City of Montgomery 2. Booker T. Johnson, Construction Operator North Montgomery Landfill, City of Montgomery 3. Jon K. Howard, Environmental Scientist North Montgomery Landfill, City of Montgomery 4. Patrick Dunson, City Engineer North Montgomery Landfill, City of Montgomery 5. Adam George, P.E., Associate Operations Director/Senior Environmental Consulting & Technology, Inc. (ECT) 6. Joe Adams, P.E., Project Manager/Engineer, CDG Engineers & Associates
Engineer
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 1 of 10
Title: Inspection Report
Effective Date: May 14, 2019
7. Gabby Sanders, P.E., Project Engineer, CDG Engineers & Associates
Report Prepared by: Kevin Taylor
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.).
Municipal Solid Waste Landfill
Title V Operating Permit No. 209-0078
3. Air permit issuance date.
06/24/2016
4. Air permit expiration date.
06/23/2021
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
Hazardous Air Pollutants (HAPs) Volatile Organic Compounds (VOCs) 40 CFR Part 60 Subpart WWW NSPS - Municipal Solid Waste Landfills
40 CFR Part 63 Subpart AAAA MACT - Municipal Solid Waste Landfills Gas Collection and Control System (GCCS)
Gas generated from the decomposition of waste is sent to a flare.
B. Process Description (provide narrative or attach description provided by the company or excerpts from the permit)
North Montgomery Municipal Solid Waste Landfill receives, manages, and disposes of solid waste, including, but not limited to, municipal solid waste, commercial waste, and industrial waste. Waste is accepted, compacted, and covered soil or other cover materials daily. Waste
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 2 of 10
Title: Inspection Report
Effective Date: May 14, 2019
decomposition produces landfill gas and leachate, both of which are managed through collection and control systems. Gas generated from the decomposition of waste is collected by a gas collection and control system (GCCS) and burned by a flare.
III. INSPECTION ACTIVITIES
Activity
Yes
Comment
No
NA
Opening Meeting
1. Date and time entered the facility.
Yes The EPA Region 4 inspectors entered the facility on March 15, 2022, at 1:20 pm (CDT).
2. Credentials presented to facility personnel (include name and title).
Yes Upon arrival, EPA Region 4 inspectors presented their EPA credentials to the facility personnel.
3. Conducted an opening meeting to explain the purpose and objectives of the inspection.
Yes The EPA Region 4 inspectors held an opening meeting with the North Montgomery Landfill personnel during which the purpose and objectives of the inspection were explained.
4. Discussed safety issues.
Yes The EPA inspectors discussed with the facility the personal safety equipment needed to conduct the inspection, emergency procedures for the facility and COVID-19 safety protocols required by EPA and the facility.
5. Discussed which records to be reviewed.
Yes Records were requested during the inspection and were initially being gathered while the inspection was being conducted. There was also a request for a copy or electronic submittal of the records, if possible, based on Covid-19 safety protocols. Due to the risk of Covid-19, the EPA inspectors wanted to limit the amount of time spent reviewing the records indoors. At the close of the
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 3 of 10
Title: Inspection Report
Effective Date: May 14, 2019
inspection, the facility stated that an official request for any records was preferred.
6. Discussed the facility walk-through Yes EPA inspectors discussed the overall
and the areas to be observed in the
inspection plan, which included looking at the
facility.
flare and monitoring ground level methane
around the perimeter and across the landfill.
7. Discussed facility policy regarding photographs or video (if applicable).
Yes 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.
8. Discussed the use of the infrared camera, TVA, PID, and any other equipment.
Yes EPA inspectors communicated the use of the infrared camera, the toxic vapor analyzer (TVA) and GPS unit for location identification.
9. Discussed CBI.
EPA inspectors requested that anything that the facility considers to be CBI be identified. The facility would also have an opportunity to review the EPA inspection report and any recorded video for CBI content prior to finalizing it. Any information identified as CBI would be treated in accordance with regulations.
Records Reviewed at the Facility
10. The types of records reviewed and the time period reviewed.
No Records were requested during the inspection and were initially being gathered while the inspection was being conducted. There was also a request for a copy or electronic submittal of the records, if possible, based on Covid-19 safety protocols. Due to the risk of Covid-19, the EPA inspectors wanted to limit
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 4 of 10
Title: Inspection Report
Effective Date: May 14, 2019
the amount of time spent reviewing the records indoors. At the close of the inspection, the facility stated that an official request for any records was preferred.
Facility Walk-Through Observations
11. The process equipment observed Yes 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.
12. The type of process parametric
N/A
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.
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 5 of 10
Title: Inspection Report
Effective Date: May 14, 2019
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
13. If process equipment or parametric N/A monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating.
14. The type of air pollution control
Yes Waste gas generated from the decomposition
equipment, the process equipment it
of waste in the landfill is collected by a gas
is controlling, and the associated
collection and control system (GCCS). The
parametric monitoring value
waste gas is sent to a utility/candlestick flare
observed (e.g., baghouse pressure
for destruction. At the time of the inspection,
drop, temperature, scrubber flow
the flare was operating and was observed
rate, etc.).
using the infrared camera.
(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 by the inspector.
Identify the permit limit (if applicable).
An attachment may be used for a large amount of information.
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 6 of 10
Title: Inspection Report
Effective Date: May 14, 2019
15. Continuous emissions monitoring N/A devices and values observed. (e.g., CEMS, COMs, etc.).
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.
16. If air pollution control equipment N/A was not operating, state the reason by facility personnel why the equipment was not operating.
17. Capture and collection system
Yes Waste gas generated from the decomposition
(enclosures and hoods)
of waste in the landfill is collected by a gas
observations, if applicable (e.g., the
collection and control system (GCCS).
magnitude and duration of emission
During the inspection, there were recorded
escaping capture from the hood).
instances of leaks and emissions using both
the TVA and the infrared camera. See
Attachment A and B.
18. Ductwork transferring the
N/A
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.).
19. Any existing unpermitted emission No points, new unpermitted emission
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 7 of 10
Title: Inspection Report
Effective Date: May 14, 2019
points, or non-permitted construction activities observed. (if yes, describe in the comments field).
20. Were any visible emissions observed? (if yes, identify the location and equipment).
21. Was a Method 9 reading performed? (if yes, identify the location and equipment).
No There were no emissions which were visible to the naked eye. However, the emissions that were observed were volatile organic emissions which are not normally detectable by sight but were observed using the TVA and/or the infrared camera. There were also emissions observed percolating from various areas that had standing water from recent rainfall. The bubbling in these areas was an indication of gases being emitted. The volatile organic emissions were then documented with the TVA and/or the infrared camera. See Attachment A and B.
No
22. Was the cause of the visible
N/A
emissions investigated and the
information documented?
23. Was a Method 22 performed for
N/A
visible emissions? (if yes, identify
the location and equipment).
24. Identify the cause of the visible
N/A
emissions as explained by facility
personnel, if applicable.
25. Was the infrared camera used? If so, attach the video log (which includes the equipment ID, and the
Yes See Video Log Attachment A
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 8 of 10
Title: Inspection Report
Effective Date: May 14, 2019
date and time the video was recorded) and videos to this report.
26. Was the TVA used? If so, identify the equipment monitored and the results.
Yes See TVA Reading Log Attachment B
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.
27. Was the PID used? If so, identify No 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.
Closing Meeting 28. Conducted a closing meeting.
29. Summarize any additional information needed, if applicable?
Yes EPA Region 4 inspectors conducted a closing meeting on March 17, 2022, at 4:30 CDT with the facility personnel and the participation of the ADEM inspector.
No No additional information was requested of the facility at the time of the inspection since the facility requested a formal information request from EPA.
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 9 of 10
Title: Inspection Report
Effective Date: May 14, 2019
30. Accept a declaration of CBI, if applicable?
No Although the CBI procedures were explained in the opening meeting and at the start of the inspection. A CBI declaration was not made at the time of the inspection. The facility was advised that an inspection report and all recorded videos and pictures would be sent to them for a CBI review following the inspection.
31. Discussed observations.
Yes EPA inspectors discussed the observations made during the inspection. This included the specific areas of elevated 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.
32. Discussed next steps, if applicable? Yes 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.
33. Date and time inspection concluded.
Yes The inspection concluded on March 17, 2022, at 4:30 CDT.
Miscellaneous
34. Include any additional observations, N/A if applicable.
Digitally signed by Taylor, Kevin
Taylor, Kevin Date: 2022.05.25 06:41:03
EPA Investigator/Inspector Signature:___________________-0_4_'0_0'_____________
Digitally signed by Groendyke,
Groendyke, Todd Todd
EPA Supervisor Signature & Title ___________________D_at_e:_20_22_.0_5._24_1_5:_21_:4_8_-0_4'0_0_' ___________________________________
Date Report Finalized:___________________________________
Project Name: North Montgomery Municipal Solid Waste Landfill
ICIS/Project No.: AL0000000110100078
Document Number: AEBFORM-012-R0
Page 10 of 10
Title: Inspection Report
Effective Date: May 14, 2019
ATTACHMENTS
1. Attachment A: 2. Attachment B:
Video and Photo Log TVA Recorded Readings Log