Document Zn6XKj6EQRdmedBMmrXp644pJ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See date of Section Chief signature CLEAN AIR ACT INSPECTION REPORT Waste Connections Brent Run Landfill, Montrose Township, MI Daniel Heins, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 16, 2021 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist 2. Emma Leeds, Environmental Engineer 3. Brianna Fenzl, Environmental Engineer Other Attendees: 1. Tim Church, District Manager - Waste Connections 2. Tanner Cavender, Gas Technician - Monitoring Control & Compliance (MCC) 3. Alex Schreiber, Project Scientist - Tetra Tech 4. Khaled Mahmood, Project Scientist - Tetra Tech Contact Email Address: timothy.church@wasteconnections.com Purpose of Inspection: To determine Clean Air Act (CAA) compliance and perform a comparative Surface Emissions Monitoring (SEM) survey 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, Title V Permit Requirements Arrival Time: 09:00 ET Departure Time: 17:30 ET Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE 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 Provided CBI warning to facility The following information was obtained verbally from Waste Connections representatives. Process Description: Brent Run Landfill (the Landfill) is a municipal solid waste (MSW) landfill located in Montrose Township, Michigan. The Landfill is a lined RCRA Subtitle D site, having started operations in 1993. Its design capacity is approximately 33 million cubic yards, with approximately 30 years of operation projected and no current expansions planned. The Landfill receives approximately 1,000 tons of waste per day, a majority of which is MSW. The Landfill accepts asbestos but not refrigerants. The Landfill is permitted for various alternate daily covers (ADC). The site primarily uses onsite soils, auto shredder fluff, and tarps as daily cover, with occasional use of contaminated soils and tire chips. There is approximately 30 acres of final cover, on the west and northwest sides of the site. Approximately 70 acres are under intermediate cover with gas collection. Approximately 10 acres are under daily cover with gas collection, on the south side, and another 23 acres are without gas collection, regardless of cover type, also on the south side. There are a final 22 acres permitted for waste that has not yet been developed. Leachate is directly routed to a neighboring publicly owned treatment works (POTW), with approximately 12 million gallons per year. Leachate is not recirculated. The gas collection and control system (GCCS) has 121 wells, including approximately 10 horizontal collectors. In areas of current waste placement where gas is collected, Waste Connections typically places vertical wells and raises them, re-drilling as needed for pinches and to potentially incorporate horizontal collectors. Waste Connections has gas collection off of the leachate system, and uses approximately 23 gas migration probes that are monitored on a quarterly basis. There are collectors for odor control outside of the footprint of the landfill that are not treated as collectors subject to full regulatory requirements. There is a pressure variance approved for the closed area of up to 19 inches of water, though Waste Connections still aims to Page 2 of 6 maintain negative pressure on these areas. Waste Connections has done surveys of liquid levels in the wells, with a survey of most wells in June 2021. There are no de-watering pumps on site. Collected gas primarily goes to a gas to energy plant owned and operated by a third party, EDL. EDL operates five reciprocating internal combustion engines. EDL does not have control over the gas collection, though EDL and Waste Connections are in communication about gas quality. The purchase agreement between the two companies incentivizes gas quality. Waste Connections has two flares at the Landfill operated on an as need basis, typically less than four weeks per year. One flare is enclosed with a capacity of 1,389 standard cubic feet per minute (scfm), and the other is open with a capacity of 1,350 scfm. Staff Interview: To determine if wells are performing adequately, technicians rely on the gas quality and pressure data from the monthly wellhead monitoring, and rely on the quarterly surface emissions monitoring (SEM) to determine if the well is collecting all of the gas that it should be. Redrills are occasionally done based off need as determined by this monitoring. Well water levels are also checked based off this monitoring. For surface emissions monitoring, contractors for Waste Connections do monitor penetrations. When EPA asked if they ever go off the planned SEM path, the contractor stated that they do not. Technicians use an Elkins IRwin, but do not log the full data, only areas above 500 ppm. SEM excludes the "hot zone" of active waste placement and any active construction area. There is no standard operating procedure (SOP) for cover integrity monitoring. EPA asked what type of cover integrity issues would warrant corrective action, and Waste Connections personnel explained that issues would need to be "excessively deep" or have exposed waste to be flagged for correction. Repairs are pending weather/season, and delayed repairs are not necessarily documented. The site is currently in the process of updating its permit to reflect regulatory changes with Part 62 Subpart OOO coming into effect and replacing Part 60 Subpart WWW. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA conducted a partial SEM survey of the facility, primarily split into two teams. Emma Leeds and Brianna Fenzl confirmed eachother's exceedances, with Khaled Mahmood providing visual confirmation of the readings taken on EPA instruments. Daniel Heins monitored as the second team with Tanner Cavender, a technician from Monitoring Control & Compliance, providing confirmation readings. Tim Church provided visual confirmation of readings when Mr. Cavender was unavailable or unable to confirm EPA's readings. EPA used three ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020) to perform EPA Reference Method 21 for the SEM. Mr. Cavendar was frequently unable to confirm readings, even of leaks exhibiting steady leak concentrations. After returning for lunch, EPA and MCC measured each other's calibration gases Page 3 of 6 with their respective instruments. EPA's three instruments found MCC's span gas, with a stated concentration of 522 parts per million (ppm), to be approximately 770 ppm. MCC's instrument, calibrated on said gas, measured EPA's calibration gases at significantly below their stated values. These readings and analysis are included in Appendix B. EPA inspectors detected and documented 38 points on the landfill with concentrations of methane above 500 ppm. Some documented points involved multiple exceedances in close proximity, such as at clustered wellheads. Multiple exceedances were at locations flagged from prior surveys that Waste Connections stated had already seen corrective action. Throughout the landfill, and particularly on the southern slope of the intermediate cover area, EPA observed recurring areas of distressed vegetation and erosion gullies. Many of these areas are documented in the Appendices A and B. EPA observed cracks, tears, and holes in GCCS equipment, as documented in Appendix A. Towards the end of the day, EPA found an increasing frequency of exceedances on the south central side of the landfill, but was only able to conduct a cursory survey of this area in the interest of concluding the inspection out of respect for the time of the site employees. Some exceedances were found at marker pipes, which were found to be effectively serving as a conduit for landfill gas to escape through the cover. Photos and/or Videos: were taken during the inspection. See Appendix A Field Measurements: were taken during this inspection. See Appendix B. RECORDS REVIEW Requested and reviewed prior to inspection: GCCS map Cover map Leachate collection system map SEM reports 2019 Q3 to 2021 Q3 2019 and 2020 semi-annual compliance reports 2020 and 2021 to date cover integrity reports 2020 wellfield data Reviewed during inspection, copy taken: Calibration gas certificate for MCC's 500 ppm gas CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Filling in the rest of the past 5 years of SEM reports, semi annuals, and cover integrity reports Current GCCS design plan Most recent performance test (as applicable) and design specifications for the flares Page 4 of 6  Past year of control device parameter monitoring (e.g. temperature and LFG flow to flare), in a spreadsheet format Summary of past 5 years of volume of gas collected (in whatever format / timeframe is easiest, be it daily, weekly, or monthly volumes) Waste accepted by category over the past year, in a spreadsheet format Most recent LandGEM report run used for estimating gas generation at the facility The June survey of well water levels discussed during the inspection Summary of the redrills & added wells that have been done over the past 5 years Compliance Assistance: EPA gave input on how to properly conduct Method 21. Concerns: EPA found a high rate of SEM hits, distinctly above historic rates. Some hits were at locations that were supposed to have been recently corrected. EPA was concerned that pipes being used as markers were effectively routing landfill gas directly to the atmosphere. Cover integrity logs were minimal, appearing to overlook issues on the landfill, and no documentation of corrective action was included. Based off the comparative readings of the calibration gases with each of the instruments, there appeared to be an issue with MCC's calibration gas, which impeded MCC's ability to take accurate readings of methane concentration. DIGITAL SIGNATURES DANIEL Digitally signed by DANIEL HEINS _H__E_IN__S________D1_7a:t3_e8:_:2305_2-_10.51_'00_.01'3____________ Daniel Heins, Report Author NATHAN Digitally signed by NATHAN FRANK FRANK Date: 2021.10.15 13:14:13 -05'00' __________________________________ Nathan Frank, Section Chief (IL/IN) Page 5 of 6 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 16, 2021 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Field Measurement Data, Including Maps Page 6 of 6 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Daniel Heins 2. Archival Record Location: ERC Enf_BrentRunWC_MI_21 "Dan Pics" Image # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 File Name 20210816_111056.JPG 20210816_111937.JPG 20210816_113744.JPG 20210816_115212.JPG 20210816_122620.JPG 20210816_123400.JPG 20210816_150606.JPG 20210816_153645.JPG 20210816_154639.JPG 20210816_155722.JPG 20210816_160109.JPG 20210816_160620.JPG 20210816_161847.JPG 20210816_162313.JPG 20210816_162633.JPG 20210816_162950.JPG 20210816_163711.JPG 20210816_164059.JPG 20210816_164427.JPG 20210816_165140.JPG 20210816_165229.JPG 20210816_165529.JPG 20210816_165854.JPG 20210816_170415.JPG Date/Time (Eastern) 2021-08-16 11:10 2021-08-16 11:19 2021-08-16 11:37 2021-08-16 11:52 2021-08-16 12:26 2021-08-16 12:34 2021-08-16 15:06 2021-08-16 15:36 2021-08-16 15:46 2021-08-16 15:57 2021-08-16 16:01 2021-08-16 16:06 2021-08-16 16:18 2021-08-16 16:23 2021-08-16 16:26 2021-08-16 16:29 2021-08-16 16:37 2021-08-16 16:40 2021-08-16 16:44 2021-08-16 16:51 2021-08-16 16:52 2021-08-16 16:55 2021-08-16 16:58 2021-08-16 17:04 Description of Image A1 - GW91R, distressed vegetation at base Example of cover integrity issues that would not be flagged for correction HC07 - crack in hose line A3 - turnaround above HC08 A5 - erosion/distressed vegetation A6 - Eroded rivulets with multiple exceedances excluded from monitoring Consultant's calibration gas, nominally 522 ppm. GW68 tear in boot A8 - GW81R2, distressed vegetation at base of well A9 - GW89R2, exceedances across entire cluster GW110, animal burrow A11 - GW111 A12 - Distressed vegetation/bare A13 - HC2 complex of exceedances A14 - Meeting of daily/intermediate cover dirt A15 - GW6B/7B mound, multiple hits A16 - dirt cover A17 - GW78. Had dirt added as corrective action post Quarter 2 A18 - GW56 A19 - Edge of tarp A19 - Edge of tarp A20 - GW55, flagged from previous attempt at correction A21 - GW54, at both points A22 - GW57 Appendices Page 1 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 1. Inspector Name: Emma Leeds 2. Archival Record Location: ERC Enf_BrentRunWC_MI_21 - "Emma Pics" Image File Name # 1 IMG_0508 2 IMG_0509 3 IMG_0510 4 IMG_0511 5 IMG_0512 6 IMG_0513 7 IMG_0514 8 IMG_0515 9 IMG_0516 10 IMG_0517 11 IMG_0518 12 IMG_0519 13 IMG_0520 14 IMG_0521 15 IMG_0522 16 IMG_0523 17 IMG_0524 Date/Time (Eastern) 2021-08-16 11:22 2021-08-16 11:43 2021-08-16 12:01 2021-08-16 12:14 2021-08-16 12:19 2021-08-16 12:26 2021-08-16 12:35 2021-08-16 3:43 2021-08-16 3:45 2021-08-16 4:02 2021-08-16 4:09 2021-08-16 4:15 2021-08-16 4:19 2021-08-16 4:24 2021-08-16 4:34 2021-08-16 4:39 2021-08-16 4:58 Description of Image B1 - distressed vegetation 50 ft NW of GW-106 B2 - distressed area 40 ft NE of GW107 B3 - HC06 distressed patch east of well B4 - erosion crack in cover, 100 ft SE of GW104 B5 - GW104 B6 - GW105, leak in air pump for valve X1 - follow up point - recently reseeded and covered with hay B7 - marker pipe NE of GW 72R Location of B7 leaking marker pipe, looking NW downhill towards scalehouse B8 - distressed grass 150 ft NW of GW81R2 B9 - erosion gully, 100 ft W of GW81R2 B10 - distressed vegetation, multiple exceedances in area. 50 ft NW of 108. B11 - GW108 B12 - HC09 B14 - 100 ft N of GW83R. Large erosion patch with gullies B13 - Large hole (1 ft wide, 1 ft deep) around GW83R B15 - erosion patch 100 ft S of GW88 Appendices Page 2 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 APPENDIX B: FIELD MEASUREMENT DATA Measured Exceedances Well / Flag Location Read. Inst. # Description 1 1 A1 GW 91R 2700 DJH A2 GW 102 1000 DJH Turnaround on road above A3 HC08 600 DJH End of SE Header (complex, including tops /bottoms of A4 marker pipes) 15% DJH Downslope of SE Header, in A5 erosion 700 DJH Mid SE Slope, multiple points in eroded A6 rivulets 900 DJH HC06 access riser and A7 nearby crack 1000 DJH A8 GW 68 GW 89R2 A9 (complex) 1.10% DJH 1800 DJH A11 GW 111 Above HC01, south mid A12 slope HC2 A13 (complex) 2600 DJH 700 DJH 2200 DJH South of haul A14 road GW 6B/7B Complex A15 mound SW of well 78, south of haul A16 road 900 DJH 1200 DJH 1400 DJH A17 GW 78 A18 GW 56 3.60% DJH 2200 DJH Read. Inst. 2 2 565 TCa 120 TCa 200 TCa 0.70% TCa 170 TCa 1200 TCa 520 TCa 2700 TCa 626 TCa 506 TCa 150 TCa 70 TCa 600 TCa 467 TCa 1434 TCa 1178 TCa Vis. Conf. TCh Latitude 43.175524 43.174512 Longitude -83.837821 -83.835853 Notes Distressed veg. 43.173368 -83.835934 Conduit, hits at all 5 penetrations, Horizontal collector below this is "not designed to get this 43.172306 -83.836587 gas" Consistent readings above 100 in TCh 43.172085 -83.8364 surrounding area Not monitored due to steepness, multiple points in TCh 43.172066 -83.835187 vicinity above 500 43.174378 -83.83443 43.174344 -83.840104 Base of well Exceedances across TCh 43.174213 -83.839151 cluster 43.174466 -83.83671 Distressed 43.173274 -83.838166 vegetation/bare TCh 43.172795 -83.838329 Meeting of daily/intermediate 43.172538 -83.838419 cover dirt 43.172539 -83.838428 Strong odors TCh 43.172197 -83.839768 In dirt. Strong odor Just hard dirt added as correction post 43.172444 -83.839335 Q2 (maybe Q1) 43.172722 -83.840877 Appendices Page 3 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 Well / Flag Location # Description A19 Edge of tarp A20 GW 55 A21 GW 54 A22 GW 57 B1 50 ft NW of GW-106 B2 40 ft NE of GW-107 B3 HC06, distressed patch directly east of well B4 100 ft SE of GW104 B5 GW104 B6 GW105 B7 base of marker pipe 10 ft NE of GW 72R B8 150 ft NW of GW 81R2 B9 erosion gully 100 ft W of GW81R2 B10 Large patch of distressed vegetation 50 ft NW of GW108 B11 GW108 B12 HC09 B13 GW83R, large hole around well (1ft wide, 1ft deep) B14 100 ft N of GW83R B15 Erosion patch 100 ft S of GW88 Read. Inst. 1 1 600 DJH 1% DJH 4400 DJH 800 DJH 1100 ELJ 700 ELJ 515 ELJ 1200 ELJ 600 ELJ 1900 ELJ 700 ELJ 600 ELJ 600 ELJ 550 ELJ 4000 ELJ 3000 ELJ 2% ELJ 700 ELJ 610 ELJ Read. Inst. 2 2 460 TCa 450 TCa 1656 TCa 801 BF 2000 BF 930 BF 1900 BF 790 BF 1300 BF 840 BF 700 BF 1500 BF 560 BF 4000 BF 1033 BF 1.30% BF 740 BF 550 BF Vis. Conf. TCh TCh TCh KM KM Latitude 43.172697 43.173295 43.173376 43.173276 43.176411 43.176325 Longitude -83.841615 -83.841386 -83.841976 -83.840708 -83.837367 -83.835518 Notes Elevated readings elsewhere along tarp edge between 100 and 500 Has flag from prior survey, was "fixed" Strong odor, exceedances at both sides Distressed vegetation Distressed vegetation KM 43.174536 -83.834731 Distressed patch Erosion crack in KM 43.173707 -83.834444 cover KM 43.173983 -83.834901 KM 43.17341 -83.835049 Marker pipe leaking directly to KM 43.174568 -83.841978 atmosphere Distressed KM 43.174298 -83.840477 vegetation patch KM 43.174102 -83.840193 Erosion gully Multiple exceedances found KM 43.173945 -83.839855 within patch KM 43.173932 -83.839639 KM 43.17374 -83.839939 KM 43.173744 -83.839581 Large erosion patch KM 43.173465 -83.839142 with gullies KM 43.17333 -83.840391 Erosion patch Appendices Page 4 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 Well / Flag Location Read. Inst. Read. Inst. # Description 1 1 2 2 Distressed 500 BF vegetation patch recently X1* reseeded By clay 550 X2* stockpile DJH *Points not flagged but noted here for completeness. Vis. Conf. Latitude Longitude Notes 43.173009 -83.834733 43.172787 -83.835998 Calibration and Instrument Information EPA used three ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020). The EPA TVA2020 response times are in the 4 to 5 second range. Emma Leeds (EL) used A56584 for the duration of the survey. Daniel Heins (DH) used C09562 for the duration of the survey. Brianna Fenzl (BF) used A56575 for the duration of the survey. Tanner Cavendar (TCa) used an Elkins IRwin for the duration of the survey. Tim Church (TCh) and Khaled Mohmood (KM) were shown readings on EPA instruments for visual confirmation of exceedances. 10:00 average calibration reading, 500 ppm gas 14:50 drift check reading, 500 ppm gas 14:50 post re-calibration reading, 500 ppm gas 17:15 end of day drift check, 500 ppm gas A56584 490 400 503 500 C09562 495 483 No Recalibration 485 A56575 492 446 494 520 EPA calibration gases Manufacturer CALGAZ GASCO GASCO GASCO Composition Air zero grade THC <1 ppm Methane in air 500 ppm Methane in air 1960 ppm Methane in air 10,000 ppm Lot # 1486172 304-402110297-2 304-402110299-1 304-402110296-1 Expiration May 2026 May 2025 May 2025 May 2025 Background readings: Upwind: -1 ppm Downwind: 1 ppm Appendices Page 5 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 Midday instrument/calibration gas comparisons with MCC Readings of the MCC span gas (stated concentration: 522 ppm): Cal Gas Source Cal Gas Stated PPM Instrument MCC 522 EPA - A56584 MCC 522 EPA - C09562 MCC 522 EPA - A56575 MCC 522 MCC Elkins IRwin EPA 500 MCC Elkins IRwin EPA 1960 MCC Elkins IRwin Instrument Reading 784 782 745 470 280 1082 Average EPA reading for MCC gas: 770 ppm Average ratio of MCC reading to calibration gas concentration, using EPA average instead of stated for MCC's gas: 0.57 In the below figure, the grey dashed line shows where a properly calibrated instrument should read for a given concentration of calibration gas. The red line shows the actual relationship between the MCC measurements and the EPA calibration gases, where on average it detects 57% of the actual concentration. When comparing against the average EPA reading for the MCC calibration gas, the response of the MCC instrument is consistent in behavior with its incorrect readings for the EPA calibration gases. Together, this indicates that the MCC calibration gas was actually approximately 770 ppm methane, rather than 522 ppm methane as stated. Appendices Page 6 of 7 Facility Name: Waste Connections Brent Run Landfill Facility Location: 8335 Vienna Road, Montrose Township, MI 48457 Date of Inspection: August 14, 2021 Map of Detected Hits SEM hit locations plotted over satellite imagery from June 7, 2015 as depicted on Google Earth. Approximate monitoring paths included, derived from GPS data. Detail view on south central portion of landfill Appendices Page 7 of 7