Document YjZYmaLq0JeJorE97NQwX6qzV

Region 2 Enforcement & Compliance Assurance Division Air Compliance Branch Inspection Date: Facility Name: Facility Address: ICIS-Air ID #: Facility Contact: EPA Lead Inspector: EPA Asst. Inspector: Other Inspector(s): State Inspector(s): 5/9/2023 CAA Inspection Report Atlantic County Utilities Authority Landfill 6700 Delilah Road, Egg Harbor Township, NJ 08232 NJ0000003400100209 Greg Seher, Director, Solid Waste Operations, 609-272-6935, gseher@acua.com Joseph Cardile, Environmental Engineer, ECAD-ACB, 212-637-4054 Victor Tu, Environmental Scientist, ECAD-ACB, 212-637-3476 Supriya Rao, EPA Environmental Engineer, LSASD-MAB, 732-321-3622 None I. Facility Background: Atlantic County Utilities Authority Landfill, which is owned and operated by the Atlantic County Utilities Authority (ACUA), is located at 6700 Delilah Road in Egg Harbor, New Jersey. ACUA landfill began accepting construction and demolition waste as well as yard waste in 1992. The landfill was approved to accept municipal solid waste in 2000. The landfill is separated into 11 cells, which contain solid waste generated from Atlantic County homes and businesses. In 2014, ACUA landfill completed construction of its final cell. In an effort to increase the disposal capacity at the landfill, ACUA constructed an earthen berm that wraps around the exterior of the landfill. The space between the newly constructed berm and the slope of the existing landfill is used to deposit additional solid waste. In addition to the construction of the berm, ACUA installed a "litter fence" on top of the landfill. The fence wraps around the perimeter of the landfill and catches litter that blows away during landfilling operations. The fence consists of 40-foot-tall posts and netting. II. Pertinent Regulatory Requirements ACUA landfill is subject to the new Federal Plan Requirements for Municipal Solid Waste Landfills, 40 CFR 62 Subpart OOO (Federal Plan, Subject OOO) and the National Emission Standards for Hazardous Air Pollutants for Municipal Solid Waste Landfills (MACT, Subpart AAAA). ACUA landfill is no longer subject to NSPS Subpart WWW. III. List of Attendees Gary Conover - ACUA, Vice President, Solid Waste Operations Greg Seher - ACUA, Director, Solid Waste Operations Sam Nutile - ACUA, System Manager, Solid Waste Operations Alvaro Alvarez - ACUA, Landfill Technician Joseph Cardile - EPA Environmental Engineer Victor Tu - EPA Environmental Engineer Supriya Rao - EPA Environmental Engineer Atlantic County Utilities Authority Landfill - NJ0000003400100209 1 5/9/2023 IV. Pre-Inspection Notification On May 3, 2023, Inspector Cardile contacted Mr. Gary Conover, Vice President, ACUA Solid Waste Operations, by telephone and subsequent email to confirm that EPA planned to conduct a Clean Air Act (CAA) inspection of the ACUA landfill on May 8-9, 2023. EPA explained that the inspection would primarily consist of surface emission monitoring (SEM) for methane leaks following EPA's leak detection and repair (LDAR) requirements applicable to this landfill. Inspector Cardile further explained that EPA was planning to conduct its own SEM during its inspection of the landfill using appropriate SEM equipment. Inspector Cardile also requested that ACUA landfill have available its staff and/or contractor who conduct SEM at the landfill at the time of EPA's inspection because EPA would like to observe ACUA and/or its contractor perform routine calibration of their monitoring equipment and conduct comparative SEM alongside the EPA inspectors. On May 3, 2023, Mr. Conover confirmed in an email sent to Inspector Cardile that representatives from his staff would be available for EPA's inspection. V. Entrance Conference On May 8, 2023, EPA Inspectors Joseph Cardile, Victor Tu, and Supriya Rao ("EPA Inspectors") arrived at ACUA's administrative facility building in Egg Harbor, NJ at approximately 9:30 AM. EPA Inspectors displayed their credentials, explained they were here to conduct a CAA inspection, and were directed to a facility conference room which was located on the first floor of the building. In the conference room, EPA inspectors were joined by several ACUA representatives including Gary Conover, ACUA's Vice President of Solid Waste Operations and Greg Seher, ACUA Director of Solid Waste Operations. EPA inspectors explained that the primary purpose of EPA's inspection was to conduct SEM of the landfill following Method 21 to monitor for methane emissions from the landfill surface and conduct a review of the facility's records related to leak detection and repair. In addition, EPA inspector planned to also observe ACUA staff and/or contractor conducting monitoring equipment calibration and performing comparative LDAR alongside EPA staff during SEM. EPA Inspectors also indicated they planned to use a Forward Looking Infrared (FLIR) Camera and a Toxic Vapor Analyzer (TVA) during the inspection. EPA inspectors were informed that SCS Engineers staff that normally perform monitoring equipment calibrations and conduct routine LDAR/SEM at this landfill were not available and would not participate on this inspection. In response, the EPA inspectors explained that since neither ACUA nor its contractor, SCS, would be conducting comparative LDAR/SEM as requested by EPA, any methane leaks identified by the EPA inspectors would be required to be repaired by ACUA staff or its contractor, as if those leaks had been discovered during the routine quarterly SEM conducted by the landfill. ACUA representatives indicated the waste footprint of the landfill is comprised of 102 acres with 21 acres under final cap/cover. The landfill consists of 11 cells in total and, at current/projected filling rates, it is anticipated that the landfill will reach capacity in October 2028. The landfill is open from 7AM to 4PM, employs approximately 250 employees, and operates 107 vertical collection wells. Due to its proximity to a local airport, ACUA implemented a nighttime landfilling operation. The landfill operates an enclosed flare that is capable of handling gas flows up to 4,000 SCFM but currently flares approximately 2,000 SCFM of gas. The landfill shut down its gas-to-energy facility and is implementing a renewable natural gas (RNG) program which would process/convert the landfill natural gas (LNG) to pipeline quality. This project is expected to be completed sometime in 2024. VI. Summary of Observations On May 8, 2023, the EPA inspectors along with ACUA landfill technician Alvaro Alvarez, began conducting SEM on ACUA landfill which lasted for two days. The EPA inspection team performed SEM and recorded leak monitoring data on the landfill. The EPA team detected and identified many methane leaks (i.e., leaks in excess of 500 ppm) throughout the landfill including several readings that exceeded 8,000 ppm. Leaks were found at the bases of wellheads, flanges, covers, vents, and pipe protrusions from the top of the rain tarps covering approximately half of the landfill surface including side slopes. The tarps, which were installed for erosion control, also act to collect, and contain landfill gas which sometimes funnels out through small tears and openings Atlantic County Utilities Authority Landfill - NJ0000003400100209 2 5/9/2023 in the tarps. Many of the tarps had leaks in excess of 500 ppm from various holes and opening and sections of the tarp were loose and ballooning in the wind. Overall, EPA inspectors completed SEM over a significant portion of the landfill's surface area and surface penetrations over the two-day timeframe. EPA Inspectors discovered 29 methane leaks in excess of 500 ppm out of 69 points sampled on the landfill. This equates to a methane leak hit rate in excess of 42%. A comprehensive list, which includes the names, locations, and the methane amounts measured at each sampled point, is included in EPA's LDAR Inspection Report (attached). VII. Closing Conference: At the closing conference, EPA inspectors explained to ACUA representatives that EPA does not provide compliance determinations on its inspections because all CAA compliance determinations required EPA supervisory review/approval. However, EPA inspectors discussed the number of methane leaks they had identified and documented while conducting their SEM. EPA inspectors also pointed out that ACUA reported only a few methane leaks in the last four calendar quarters while conducting SEM of the entire landfill in each of those quarters. EPA inspectors re-stated that the leaks they had identified during SEM would need to be repaired and re-monitored as required by the regulations and the list of leaks identified by EPA would be provided to ACUA via email within the next few days. The leak information was sent to ACUA via email on May 19, 2023. It was also agreed at the closing meeting that the required timeframe to repair these leaks would start upon ACUA's receipt of EPA's leak results. This concluded EPA's inspection and the EPA inspectors left the landfill at approximately 5 PM EST on May 9, 2023. Enclosure: EPA's LDAR Inspection Report with attachments, dated July 6, 2023 Atlantic County Utilities Authority Landfill - NJ0000003400100209 3 5/9/2023 Lead Inspector's Name: Joseph Cardile Cardile, X Joseph Digitally signed by Cardile, Joseph Date: 2023.07.10 15:57:33 -04'00' Lead Inspector Assisting Inspector's Name: Victor Tu VICTOR X TU Digitally signed by VICTOR TU Date: 2023.07.10 15:43:46 -04'00' Assisting Inspector Supervisor's Name: Francesco Maimone FRANCESC Digitally signed by FRANCESCO MAIMONE X O MAIMONE Date: 2023.07.10 16:19:38 -04'00' Supervisor Atlantic County Utilities Authority Landfill - NJ0000003400100209 4 5/9/2023 Participating Personnel: Report Prepared by: Lead Inspector: Approved by: Leak Detection and Repair (LDAR) Inspection Report Atlantic County Utilities Authority Landfill 6700 Delilah Road Egg Harbor Township, NJ 08232 AIRS ID: NJ0000003400100209 Inspection Date: May 8-9, 2023 US Environmental Protection Agency Supriya Rao, PE, Environmental Engineer Victor Tu, Environmental Engineer Joseph Cardile, Environmental Engineer 07/05/23 Supriya Rao, PE Environmental Engineer Monitoring and Assessment Branch 07/05/23 ___________________________________________ Supriya Rao, PE Environmental Engineer Monitoring and Assessment Branch CAROL LYNES Digitally signed by CAROL LYNES Date: 2023.07.06 15:35:11 -04'00' Carol Lynes, Chief Monitoring and Assessment Branch LDAR Inspection of Atlantic County Utilities Authority Landfill, NJ Table of Contents: Leak Detection and Repair Report Introduction Management System Review Technical System Audit Compliance Monitoring Follow-Up Areas of Concern Page 2 of 5 1-5 3 3 4 4 5 5 Attachments 1 LDAR Monitoring Data 2 ARCGIS Map LSASD/MAB/AWQAT AIRS ID: 34-001-00209 Atlantic County Utilities Authority Landfill Egg Harbor Township, NJ Page 3 of 5 Inspection Date: May 8-9, 2023 Introduction: The Atlantic County Utilities Authority Landfill (ACUA) in Egg Harbor Township, New Jersey is owned and operated by ACUA. The landfill accepts predominantly municipal solid waste, construction debris, and bulk waste. ACUA has placed waste in eleven cells, Cells 1 and 2 are closed with final cover. Cells 5, 6, 7, 8, 9 are being actively filled. Cells 3, 4, 10, 11 have temporary cover/cap in place. ACUA continues to conduct the operation of placing waste in the active landfill cells during nighttime. This unique nighttime operation is conducted due to its proximity to the local airport. There are various horizontal and vertical gas collectors in Cells 1 to 11 in the landfill. ACUA owns and operates the Gas Collection and Control System (GCCS) system onsite, maintains the well heads, and controls the flare. ACUA's contractor, SCS Field Services performs all of the quarterly surface emissions monitoring at the landfill. ACUA is subject to 40 CFR 62, Subpart OOO, Federal Plan Requirements for Municipal Solid Waste Landfills That Commenced Construction on or before July 17, 2014, and Have Not Been Modified or Reconstructed Since July 17, 2014, and 40 CFR 63 Subpart AAAA, National Emission Standards for Hazardous Air Pollutants for Municipal Solid Waste Landfills As per 40 CFR 62 Subpart OOO (62.16716(d)) and 40 CFR 63 Subpart AAAA (63.1958(d)), the landfill is required to develop and implement a surface emissions monitoring plan in which testing is conducted around the perimeter with a pattern that traverses the landfill at 30-meter intervals. Management System Review: Objective: A management system review consists of an evaluation of the facility's current Leak Detection and Audit Review (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 past reports, monitoring data, component leak histories, calibration gas certificates of analysis, calibration logs, calibration precision testing, and calibration response time testing. Observations: ACUA's contractor, SCS Field Services, performs all surface emissions monitoring at the landfill. Any instrument reading greater than 500 ppm is considered an exceedance. If an exceedance is found by SCS Field Services, a GPS location is taken, the area is flagged, and the landfill management is notified. ACUA is responsible for cover maintenance and will add dirt or clay to the surface if necessary. LSASD/MAB/AWQAT AIRS ID: 34-001-00209 Atlantic County Utilities Authority Landfill Egg Harbor Township, NJ Page 4 of 5 According to ACUA, re-monitoring is performed by SCS Field Services within 10 days. If the area passes re-check, follow-up monitoring is performed within 30 days. If the area does not pass the re-check, another attempt at repair is made, and re-monitoring is performed within 10 days. EPA Inspectors reviewed the quarterly surface emissions monitoring reports from June 2022 to March 2023. Technical System Audit: 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: ACUA's surface monitoring contractor, SCS Field Services, was not present during EPA's inspection. Therefore, there are no observations to report about the instrumentation/calibration procedures and calibration gases used by SCS Field Services. 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 and provided as Attachment 1 to this report. Observations: Side by side surface monitoring could not be conducted as SCS Field Services was not present during EPA's inspection; however, EPA did continue its own LDAR monitoring of the landfill. All results were relayed verbally in the field to ACUA's Mr. Alvaro Alvarez and by email afterwards on. Monitoring results are included in Attachment 1 to this report. Calibration of the TVA2020 was completed in the field prior to starting the surface emissions monitoring. The following calibration gases 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 Attachment 1. A total of 69 points were monitored over the two-day period. Any reading above 500 ppm is considered a leak ((62.16716(d)) and (63.1958(d)). As shown in LSASD/MAB/AWQAT AIRS ID: 34-001-00209 Atlantic County Utilities Authority Landfill Egg Harbor Township, NJ Page 5 of 5 Attachment 1, EPA detected 29 leaks, which equates to a leak rate of 42%. A majority of the leaks found were located at base of the wells, located in the landfill section covered with the black tarp. Region 2 inspectors used ArcGIS Maps on iPhone XR to record the coordinates of each point monitored at ACUA. Coordinates for each point monitored can be found in Attachment 1. Follow-Up: At the closing conference held on May 9, 2023, Region 2 inspectors reviewed all the findings of the inspection with ACUA personnel (Gary Conover, Greg Seher, Sam Nutile and Alvaro Alvarez). On May 20, 2023, Joseph Cardile forwarded Mr. Gary Conover the requested exceedances table with all exceedances locations and requested follow-up repair and monitoring data for all leaks found during the inspection. ACUA sent the initial 10-day monitoring data on May 31, 2023. On June 1, 2023, Joseph Cardile acknowledged receipt of the data as well as requested that supporting documentation of repairs to be included with the 30 days recheck monitoring and submittal. ACUA provided the 30-day re-monitoring data and pictures of the repairs conducted on June 20, 2023. Areas of Concern: During EPA's Surface Emission Monitoring, a total of 29 locations with gas readings exceeding 500 ppm were identified. During the last quarterly gas monitoring completed by SCS Field Services in March 2023, six penetration locations were identified with readings above 500 ppm. SEM reports were reviewed from the time period of June 2022 to March 2023. The second quarter 2022 SEM report listed exceedances at seven penetration monitoring points. The third quarter 2022 SEM report listed exceedances at thirteen penetration monitoring points. The fourth quarter 2022 SEM report listed exceedances at three penetration monitoring points. EPA has detected a significantly greater number of exceedances during the surface emission monitoring. Despite EPA's request, SCS Field Services did not have a monitoring technician or monitoring equipment available during EPA's inspection. It is recommended that ACUA's surface emissions monitoring contractor, SCS Field Services, reevaluate the requirements of Method 21 to ensure proper monitoring techniques are being utilized during the quarterly monitoring in order to correctly identify the number of gas exceedances over 500 ppm methane. LSASD/MAB/AWQAT AIRS ID: 34-001-00209 Atlantic County Utilities Authority Landfill Egg Harbor Township, NJ ATTACHMENT 1 TVA READINGS United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Atlantic County Landfill/Atlantic County Utility Authority 6700 Delilah Road, Egg Harbor Twp, Atlantic County, NJ Date of Inspection: May 8 -9, 2023 Weather: 700 F, Sunny, Wind 8 MPH, Visibility - Clear Sample ID Downwind Upwind Upwind Pump station # 6 Pump Station # 5 Pump Station # 4 Runoff opposite to Pump station #4 Pump Station # 2 Manhole 1557-2013 Well 58A Well # 11 Well # 58 Penetration #1 Penetration #2 Penetration #3 Horizontal collector @ flange Penetration # 4 Penetration # 5 Horizontal collector off well 121 Well 121 Horizontal collector close to well 125 Horizontal collector close to well 100 Well 100 @base Well 99 @ base Well 105 @ base Well 106 @header Horizontal collector near well 112 H51 @ header H48 @bottom of header pipe Well 113 @jacket sleeve Concentration (ppm) 1.0 1.5 1.5 24 57 2 1.8 6.8 1.8 4.6 15.6 4.8 6346 1153 16.8 587 10100 10600 804 1.8 508 2.8 23 142 4.8 6002 17.8 824 10100 17400 Latitude 39.425808 39.423720 39.423715 39.424377 39.424471 39.424579 Longitude -74.539584 -74.542271 -74.542269 -74.535899 -74.537221 -74.538426 Notes/Comments Near lookout tower 39.424646 39.424236 39.424611 39.425855 39.426053 39.425662 39.426572 39.426563 39.426532 39.426388 39.426324 39.426280 -74.538613 -74.539494 -74.542927 -74.538761 -74.539519 -74.539273 -74.539255 -74.539248 -74.539254 -74.539532 -74.539651 -74.539680 39.426205 -74.539967 39.426166 -74.540323 C&D meets MSW area 39.429423 -74.538780 39.429476 39.429583 39.430116 39.429971 39.430069 39.429918 39.430028 39.429908 39.429558 -74.538189 -74.537843 -74.537889 -74.538390 -74.538893 -74.539375 -74.539432 -74.539640 -74.539838 United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Atlantic County Landfill/Atlantic County Utility Authority 6700 Delilah Road, Egg Harbor Twp, Atlantic County, NJ Date of Inspection: May 8 -9, 2023 Weather: 700 F, Sunny, Wind 8 MPH, Visibility - Clear Sample ID H53 @sleeve near header H54 @sleeve near header Well 108 Well 109@base Horizontal on top of well 109 @sleeve of bottom Well 18R @ header Well 16R Well 17R Well 123 @base Well 124 @flange Well 89 @base Well 95 @flange Well 91 @flange Well 90 Protrusion near header elbow pipe Well 94 @base Header for well 95 @base Well 21A Well 130 @base Well 132 Header for Well 132 Header for well 133 Dirt mound near Well 129 Well 154R Well 136R Well 153R Header for Well 153R Well 137R Well 155R Soil near Well 155R Well 138R @base Well 139R Concentration (ppm) 6834 4436 238 2067 2896 118 24 14.5 2067 8.8 1252 34.5 8.5 5.5 10100 1767 508 1357 148 7.8 1630 6897 1020 323 249 316 17.5 626 412 599 54 11.2 Latitude 39.429487 39.429272 39.429167 39.428759 Longitude -74.539529 -74.539653 -74.539674 -74.539793 39.428807 39.427014 39.426936 39.427976 39.428137 39.428474 39.428638 39.428880 39.428891 39.428914 -74.539338 -74.537444 -74.537732 -74.537971 -74.538502 -74.538655 -74.538356 -74.537873 -74.537868 -74.537851 39.429185 39.428583 39.428876 39.427176 39.426783 39.426632 39.426682 39.426457 39.426331 39.426155 39.426152 39.426167 39.426594 39.426472 39.426267 39.426265 39.425874 39.425432 -74.537482 -74.537442 -74.536831 -74.536446 -74.536138 -74.536125 -74.535692 -74.535342 -74.535979 -74.534704 -74.534692 -74.534682 -74.534635 -74.534259 -74.534088 -74.534081 -74.533775 -74.533961 Notes/Comments United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Atlantic County Landfill/Atlantic County Utility Authority 6700 Delilah Road, Egg Harbor Twp, Atlantic County, NJ Date of Inspection: May 8 -9, 2023 Weather: 700 F, Sunny, Wind 8 MPH, Visibility - Clear Sample ID Well 152 Leachate clean out pump station # 9 Base of pipe at back of pump station # 9 Flange at Pump Station 8S Pipe behind Pump Station 8S @base Flange at Pump Station 10 Concentration (ppm) 389 599 8899 4.6 566 3.4 Latitude 39.419666 Longitude -74.524878 39.424488 -74.515547 39.425589 -74.532592 39.428076 -74.534504 39.428028 -74.534519 39.430084 -74.536170 Notes/Comments ATTACHMENT 2 ARCGIS MAP