Document Ra90E7arv3LzNejLKBBmx92LB
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
SUBJECT: FROM: THRU: TO:
CLEAN AIR ACT INSPECTION REPORT Waste Management Countryside Landfill, Grayslake, Illinois
Brianna Fenzl, Environmental Engineer AECAB (IL/IN)
Nathan Frank, Section Supervisor AECAB (IL/IN)
File
BASIC INFORMATION
Facility Name: Waste Management Countryside Landfill
Facility Location: 31725 IL-83, Grayslake, IL 60030
Date of Inspection: September 30, 2021
EPA Inspector(s): 1. Brianna Fenzl, Environmental Engineer 2. Karina Kuc, Environmental Engineer 3. Brittany Cobb, Environmental Engineer 4. Alexandra Letuchy, Environmental Engineer 5. Tess Russell, Environmental Engineer
Other Attendees: 1. Steve Niehoff, Director of Air Programs, Waste Management 2. Matt Raine, Gas Operations Manager, Waste Management 3. Brad Stenzel, Operations Manager, Waste Management
Contact Email Address: sniehoff@wm.com
Purpose of Inspection: To determine Clean Air Act (CAA) compliance and perform a comparative Surface Emissions Monitoring (SEM) survey
Facility Type: Municipal solid waste (MSW) landfill
Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart WWW; 40 C.F.R. Part 63, Subpart AAAA, Permit Requirements
Arrival Time: 11:00 AM Departure Time: 3:16 PM
Inspection Type: Unannounced Inspection Announced Inspection
OPENING CONFERENCE
Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility
The following information was obtained verbally from Waste Management representatives unless otherwise noted.
Process Description: Countryside Landfill (the Landfill) is a municipal solid waste (MSW) landfill located in Grayslake, Illinois. The Landfill opened in 1974. The site consists of 136 acres, of which 24 acres are under final cover and an additional 20 acres will be placed under final cover this year. Waste Management expects to close the landfill in 5.5 years. The North and South expansions are lined. Cells 4 and 5 are the two active cells. Cell 1 was the original cell and was closed in the early 2000s. Cells 2 and 3 stopped filling in approximately 2013-2014.
The Landfill accepts about 2000 tons of waste per day. The makeup of waste is approximately 40% MSW, 40% special soils and related waste, 5-10% construction and demolition, and 5-10% asbestos. As of 2016, the Landfill has accepted less drywall, and since then sulfur levels have been down. The Landfill does not accept refrigerants.
The gas collection and control system (GCCS) has an estimated 132-134 gas wells. For methane leaks found during surface emissions monitoring (SEM), bentonite is placed around wells to resolve the leak. There are two 4200 standard cubic feet per minute (scfm) capacity flares on site. Landfill gas can be routed to a third-party gas to energy plant across the street. When the plant is down, Waste Management operates one or both of the flares.
There are 4 collection points for leachate. Approximately 6 loads per day of leachate are disposed of at the Fox River treatment plant.
Page 2 of 5
Staff Interview: There are about 10 employees on site. Waste Management has a third party, Environment Management Technologies (EMT), perform SEM at the Landfill. Waste Management told EPA that they average 2-3 hits per year during routine SEM. All hits were found at wells. Waste Management told EPA that the monitoring technician would not move off SEM path unless there were visual indications of leaks.
In the 3rd quarter of 2021, it will be the first time EMT will be monitoring at penetrations.
Odor complaints received by Waste Management have been down this year (2-3) from last year (5). Countryside does not cover with wood chips as often for daily cover, which keeps odors down. Daily cover is typically soil or contaminated soil.
Matt Raine informed EPA that the gas-to-energy plant has been shut down and empty for months and does not plan to reopen. Waste Management plans to build a gas-to-energy plant on site and have it in operation in a couple years. It will be run by a third party.
TOUR INFORMATION
EPA Tour of the Facility: Yes
Data Collected and Observations: Two EPA inspectors performed Method 21 SEM at the Landfill with three inspectors assisting with notes and GPS equipment. EMT and Waste Management both confirmed readings made by EPA inspectors.
Methane values that were higher than 500 parts per million (ppm) are considered an exceedance. Most of the observed exceedances were at wells, in addition to a few at areas other than gas wells. There was a total of 33 exceedances found and documented by EPA.
The team handling TVA #CO9662 was unable to take photos of the area surrounding all but two of their exceedances because their camera failed.
Only one of the flares on site was operating.
Photos and/or Videos: were taken during the inspection. See Appendix A.
Field Measurements: were taken during this inspection. See Appendix B.
RECORDS REVIEW
1. Map of landfill and Gas Collection Control System
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CLOSING CONFERENCE
Provided U.S. EPA point of contact to the facility
Requested documents: x Results of 3Q21 SEM event x Past two years of SEM Reporting x Gas Collection and Control System Map x Four most recent semi-annual reports x Most recent depth-to-water measurements x Past year of wellhead monitoring records
Concerns: EPA inspectors informed Countryside Landfill of methane leaks found during the inspection.
DIGITAL SIGNATURES
Digitally signed by BRIANNA
BRIANNA FENZL FENZL
Report Author: __________________D_a_te_: 2_02_1.1_2_.02_1_3:3_6_:58_-0_6_'00_'
Frank,
Nathan
Digitally signed by Frank, Nathan Date: 2021.12.03 16:59:14 -06'00'
Section Supervisor:_________________________________
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Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake, IL 60030 Date of Inspection: September 30, 2021 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log 2. Appendix B: Field Measurement Data 3. Appendix C: Exceedance Area Observations
Page 5 of 5
Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake Date of Inspection: September 30, 2021
APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Karina Kuc
2. Archival Record Location: One Drive File
Image Number
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32
File Name IMG_8115.JPG IMG_8116.JPG IMG_8117.JPG IMG_8118.JPG IMG_8119.JPG IMG_8120.JPG IMG_8121.JPG IMG_8122.JPG IMG_8123.JPG IMG_8124.JPG IMG_8125.JPG IMG_8126.JPG IMG_8127.JPG IMG_8128.JPG IMG_8129.JPG IMG_8130.JPG IMG_8131.JPG IMG_8132.JPG IMG_8133.JPG IMG_8134.JPG IMG_8135.JPG IMG_8136.JPG IMG_8137.JPG IMG_20210930_140908973 IMG_20210930_141313658 1A3C8029.JPG 3EE56385.JPG 4C3AF494.JPG C810BD1F.JPG CF9C5EC8.JPG E4095723.JPG F423D816.JPG
Date and Time (incl. time zone and DST) 2021:09:30 12:23:37 2021:09:30 12:28:59 2021:09:30 12:42:27 2021:09:30 13:03:04 2021:09:30 13:05:46 2021:09:30 13:09:08 2021:09:30 13:11:37 2021:09:30 13:13:49 2021:09:30 13:21:13 2021:09:30 13:21:24 2021:09:30 13:22:35 2021:09:30 13:52:23 2021:09:30 13:57:12 2021:09:30 13:58:01 2021:09:30 14:02:35 2021:09:30 14:16:33 2021:09:30 14:16:37 2021:09:30 14:16:45 2021:09:30 14:23:04 2021:09:30 14:24:52 2021:09:30 14:24:54 2021:09:30 14:30:47 2021:09:30 14:38:07
2021:09:30 14:09 2021:09:30 14:13 2021:09:30 12:51 2021:09:30 14:03 2021:09:30 13:54 2021:09:30 13:24 2021:09:30 12:38 2021:09:30 12:25 2021:09:30 13:04
Description of Image Exceedance 13 Exceedance 14
Photo of top of landfill Exceedance 18 Exceedance 19 Exceedance 20 Exceedance 21 Exceedance 22 Exceedance 23
Exceedance 23 Second Photo Exceedance 24 Exceedance 25 Exceedance 26 Exceedance 27 Exceedance 28 Exceedance 29
Exceedance 29 Second Photo Exceedance 29 Third Photo
Exceedance 30 Exceedance 31 Exceedance 31 Second Photo Exceedance 32 Exceedance 33 Exceedance 10 Exceedance 11 Exceedance 3 Exceedance 9 Exceedance 8 Exceedance 5 Exceedance 2 Exceedance 1 Exceedance 4
Appendices Page 1 of 5
Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake Date of Inspection: September 30, 2021
APPENDIX B: EXCEEDANCE AREA OBSERVATIONS
Image Number 1 2 4 5
6
7 8 15 16 17 19 20 21 24 26 28 29 30 31 32
Observations Dry and cracked vegetation surrounding well Distressed, dead vegetation surrounding well Heavily distressed area surrounding well Dry and cracked, evidence of dried, previously pooled, area surrounding well Dry and cracked, evidence of dried, previously pooled, area surrounding well Rocky area surrounding well Rocky area surrounding well Rocky distressed area surrounding well Rocky, heavily distressed area surrounding well Rocky, heavily distressed area surrounding well Distressed soil surrounding well Exposed trash around well Exposed trash around well Distressed, dead vegetation Soft, newish cover Open pipe, dead vegetation Cracks in ground, distressed area Dry, cracked area surrounding well Rocky area with pipes in ground Dry, cracked area surrounding well
Appendices Page 2 of 5
Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake Date of Inspection: September 30, 2021
APPENDIX C: FIELD MEASUREMENT DATA
Calibration with 0, 500, 2000, 1% ppm methane gas, done by EPA at 10:00 AM
TVA #CO9562
TVA #SL1555
Calibration Methane Reading (ppm)
Methane Reading (ppm)
Gas (ppm)
0
-2
-1.5
500
490
487
2000
2020
1961
1.00%
1%
1.03%
Bump check data with 500 ppm methane gas, done by EPA at 11:45 AM
TVA #CO9562
TVA #SL1555
#1
515
470
Background methane data, done by EPA at 2:50 PM
ppm
Upwind
-0.7
Downwind 4.5
Exceedance Measurements, done by EPA SEM
TVA #CO9662
Exceedance Location
ppm (or %) VOC
as methane
EPA Inspector with TVA
1
Well 162
1200
2
Nearby Well 164R 855
3
Well 216
846
4
Well 107
1554
42.320373, -
88.020886, NE
5
Section of Cell 4
817
42.320365, -
88.021167, NE
6
Section of Cell 4
535
42.320232, -
88.021667, 65 ft SW
7
of Well 11R2
1497
Brittany Cobb Brittany Cobb Brittany Cobb Brittany Cobb Brittany Cobb
Brittany Cobb
Brittany Cobb
Confirmation Reading
754
EMT or Waste Management confirmed EMT
770
EMT
Not confirmed 1881
EMT
418
EMT
Not
-
confirmed
Not
-
confirmed
Appendices Page 3 of 5
Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake Date of Inspection: September 30, 2021
8
Well 209
2300
9
Well 114R2
1177
42.321000, -
88.023671, 5 ft W of
10
Well 114R2
650
42.321154, -
88.024258, 30 ft W
11
of Well 41R2
2005
12
Well 247
686
TVA #SL1555 Exceedance Location
ppm (or %) VOC as methane
13
CSHL0022
600
14
Well 223
1.00%
15
Well 224
4800
16
Well 241
1.00%
17
Well 225
570
18
Well 156R2
570
19
Well 201R3
2800
20
Well 207R2
1000
21
Well 123R3
2400
22
Well 206R2
1.00%
23
Well 203R3
612
24
Well 204R3
3800
25
Well 128R
650
Brittany
2604
Cobb
Brittany
661
Cobb
Brittany
509
Cobb
Brittany
764
Cobb
Brittany
520
Cobb
EMT EMT EMT
EMT
EMT
EPA Inspector with TVA Tess Tess Tess Tess Tess Tess Tess Tess Tess Tess Tess Tess Tess
Confirmation Reading
640 1.00% 5000 2000 560 570 560 1000 1000 780 630 680 630
EMT or Waste Management confirmed Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management
Appendices Page 4 of 5
Facility Name: Waste Management Countryside Landfill Facility Location: 31725 IL-83, Grayslake Date of Inspection: September 30, 2021
26
Well 115R
750
Tess
820
27
Well 129R2
3000
Tess
1000
28
Well 236
2.00%
Tess
4.00%
29
Well 69R2
3000
Tess
2700
30
Well 228
1200
Tess
1100
31
HC57
5000
Tess
2000
32
Well 214
4000
Tess
3000
33
0018 labeled, riser by 800
flare 1
Tess
760
Bump check data with 500 ppm methane gas, done by EPA at 2:55 PM
TVA #CO9562
TVA #SL1555
#2
503
485
Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management Waste Management
Calibration Data and Instrument Information
Calibration Gas (ppm)
Lot Number
0
#1501788
500
#304-402110297-1
2000
#1434290
1.0%
#1440891
Brittany Cobb and Sasha Letuchy used TVA #CO9562. Tess Russell and Karina Kuc used TVA #SL1555.
Expiration Date 6/2026 5/11/25 6/2026 6/2026
Appendices Page 5 of 5
