Document aJvekr5220xy2EpaLo808pqEa

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT WM Autumn Hills RDF Landfill, Zeeland, MI FROM: Emma Leeds, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: WM Autumn Hills RDF Landfill, Zeeland, MI Facility Location: 700 56th Avenue, Zeeland, MI 49464 Date of Inspection: September 13, 2024 EPA Inspector(s): 1. Emma Leeds, Environmental Engineer 2. Sasa Dunovic, Environmental Engineer 3. Giles Chickering, Environmental Engineer 4. Karina Kuc, Environmental Engineer 5. Jacob Herbers, Environmental Engineer Other Attendees: 1. Matt Rosser, District Manager - WM 2. Chris El-Cassabgui - Environmental Protection Specialist - WM 3. Joshua Wells, LFG Technician - Diversified Technologies, Inc. (DTI) (only in field) 4. Eric Ahrnes, LFG Technician - Diversified Technologies, Inc. (only in field) 5. Jim Mohney, Gas Operations Manager - WM (only in field) 6. Bob Pliska, Regional Engineer - WM (only in field) 7. Chris Robinson, Environmental Quality Analyst - Michigan Department of Environment, Great Lakes, and Energy (EGLE) 8. Jeff Benya, Environmental Quality Analyst - Michigan EGLE Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 Contact Email Address: bpliska@wm.com ; mrosser@wm.com Purpose of Inspection: To determine compliance with the Clean Air Act (CAA) and to perform a comparative Surface Emissions Monitoring (SEM) survey Facility Type: Municipal solid waste landfill Regulations Central to Inspection: 40 C.F.R. Part 62 Subpart OOO - Federal Plan Requirements for Municipal Solid Waste Landfills; 40 C.F.R. Part 63 Subpart AAAA - National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills Arrival Time: 8:45 AM ET Departure Time: 2:20 PM 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 WM and DTI personnel unless otherwise noted. Process Description: Autumn Hills Landfill ("the Landfill" or "the Facility") is an MSW landfill that has operated since 1992 and has an estimated 35 years until closing. Most of the landfill was under intermediate cover and no parts were under final cover at the time of the inspection. The facility typically accepts approximately 35% special waste, 45% MSW, and 20% construction and demolition waste. Special waste includes, but is not limited to, spent paint, powder coat (residue from painting cars), sludges, and contaminated soils. All waste is comingled. The landfill gas (LFG) collection system has 171 vertical and horizontal extraction wells in total (facility personnel was not sure how many were vertical versus horizontal). All new wells are installed with a dewatering pump. In recent years the facility has been installing wells by "rock drilling", which involves adding stone pads at various vertical levels as waste is added, and then drilling a well down through the pads when the landfill reaches final grade. This method is intended to prevent heat accumulation in the landfill. SEM and monthly cover integrity checks are performed by a third-party contractor, Diversified Technologies, Inc. Page 2 of 13 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 LFG from the Landfill is predominately sent to the Kinder Morgan facility for treatment and is then sent to Zeeland Farm Services (ZFS) where it is used to produce heat and steam for their process. The only treatment for LFG at the Landfill itself is a knock-out pot for removing moisture. A 3,000 standard cubic feet per minute (scfm) capacity utility flare is used at the Landfill as a back-up if Kinder Morgan has a shutdown and for any excess gas. The Landfill uses the LGMS well tracking system to extract and collect only LFG that contains methane in concentration between 50-52% A solidification process is performed in an area located on the southwestern side of the top of the Landfill, where WM mixes autofluff, ash, liquid caster slag, and other fine wastes with sludges that contain more than 10% liquids. The fines and liquid wastes are mixed in a steel pit in the Landfill using an excavator, and then dried in an oven, before being deposited onto the Landfill. Leachate is collected from the Landfill using 8 sump pumps and is stored in a 250,000 gallon tank before being injected into an on-site deep injection well. About 56,000 gallons of leachate per day have been injected into the well for the past year and a half. Staff Interview: The waste acceptance rate has been doubling for the past few years, up to 3,500 tons per day at the time of the inspection, after the Landfill entered a contract with the Kent County waste to energy (WTE) facility. The Kent County WTE facility sends the Landfill any excess solid waste it receives and doesn't have the capacity to burn. The Facility is in the process of building a renewable natural gas (RNG) plant, where it plans to send LFG gas when complete rather than to ZFS. At the time of the inspection, about 2,100 scfm of LFG was being sent to Kinder Morgan/ZFS, and 140 scfm of LGF was being sent to the on-site flare. Hydrogen sulfide at the flare was reading around 300 parts per billion. The most recent construction on the GCCS included installing 8 new LFG extraction wells in cell 16. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA began their SEM inspection at 10:07 AM on the southwest corner of the landfill accompanied by Josh Wells from DTI, while Jeff Benya from EGLE began his SEM inspection on the eastern portion of the landfill accompanied by Eric Ahrnes. EPA took measurements with two Inficon IRwins (IRwin) and two Thermo Fischer Toxic Vapor Analyzer 2020 devices (TVA). Inspectors split into two groups, each equipped with one IRwin to record exceedances of methane above 500 ppm and one TVA to provide confirmation readings for any exceedances. The IRwin and TVA probe inlets were held 10 centimeters (cm) from the ground during SEM, with the probe inlet taped 10 cm from the bottom of the walking sticks on the Irwins. Page 3 of 13 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 About 20 minutes into performing SEM, WM instructed EPA and EGLE to get off the landfill for safety reasons but couldn't elaborate on what exactly the concerns were when asked. WM instructed EPA and EGLE to drive back to the main office, where they were told that personnel from the corporate WM office requested that no one return back onto the landfill until the Gas Operations Manager Jim Mohney, who was more than an hour away, arrived at the facility with Blackline Safety devices. EPA questioned what had changed since they were initially allowed out with Josh Wells and Eric Ahrnes who traverse the landfill regularly. Matt Rosser called corporate WM again, and then informed EPA that the two Blackline Safety devices that were already on-site were actually sufficient, and they were allowed back out. EPA resumed their SEM inspection in the northeast portion of the Landfill at 11:15 AM, moving up the northern slope towards the top plateau of the landfill. EPA approached the flat top area, which appeared sandy and had sparse vegetation throughout, but was told they were not allowed onto the actual plateau because it was an active area for the solidification process. EPA asked why this area was considered active if there were no trucks or construction nearby and vegetation growing on the waste piles, but WM personnel stated they were repeating orders from above. EPA also stated that maps in the facility's quarterly SEM reports show that SEM is performed in this area, but Josh Wells stated that the maps must be incorrect because he knows the technicians who perform SEM have never monitoring in this flat top area. Monthly wellhead monitoring for the wells in this area is still performed. EPA requested several times to perform SEM in this area but were continuously denied. In summary, EPA logged 29 separate exceedances, many of which represented multiple penetrations or broader areas of exceedance. Six exceedances were located at wellhead penetrations, while the remaining 23 exceedances were located in areas where poor cover had lead to elevated emissions, including areas with distressed to no vegetation, cracks or erosion gullies. A majority of exceedances were more than double the surface methane standard, and 11 exceedances were at least 4 times the surface methane standard. Additionally, EPA identified two marker pipes protruding from the landfill's cover that were releasing LFG containing 8,000 and 10,000 ppm of methane (Images #38 and #45). Jeff Benya from Michigan EGLE performed a separate concurrent SEM survey on the eastern part of the landfill, finding 15 exceedances above 500 ppm methane. Jeff Benya used a LandTec SEM5000 device to perform SEM. Furthermore, EPA identified and documented several locations with cover integrity issues. Several areas with distressed vegetation, different-sized bare patches, and exposed waste were also noticed. See Notes About Cover Integrity, Appendix D, for more notes on these locations. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were taken during this inspection and are listed in Appendix B. EPA performed surface emissions monitoring of methane emissions at the landfill using 2 Irwin devices and 2 TVAs. Page 4 of 13 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 RECORDS REVIEW EPA briefly reviewed the facility's cover integrity monitoring plan "BMP-LFG-123", cover monitoring reports from January to May 2024, and the most recent quarterly SEM reports. As shown in Images 1 and 2, the cover integrity monitoring plan includes a list and photos of specific cover integrity issues that should be recorded and addressed, including surface cracking, leachate breakouts and developing leachate breakouts, and flagging waste. No cover integrity issues had been noted in any of the monthly reports, and one photo of the cover was taken per month. The most recent SEM reports showed few to no exceedances in each quarter. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Requested documents: Quarterly SEM reports from 2023 Q1 to the present NESHAP Semi-Annual reports from 2023 H1 to the present Monthly cover integrity logs from January 2023 to the present Most recent phase map of the Landfill displaying active (both the solidification and filling areas), intermediate, and final cover Most recent as-built map of the GCCS LFG flow rate records (scfm) from main header, and also separate flow rates to ZFS and the flare, since January 1, 2023 Concerns: EPA expressed concerns that WM had been finding little to no SEM exceedances during their quarterly surveys when EPA found 29 exceedances in less than 3 hours of monitoring. EPA also expressed concern that no SEM is being conducted on the top of the landfill when only a small portion involves the active solidification process. DIGITAL SIGNATURES Leeds, Digitally signed by Leeds, Emma Date: 2024.11.08 Report Author: _E__m_m__a________1_3:0_6_:53_-_06_'0_0'____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2024.11.08 _N__a_t_h_a_n_______1_4:0_4_:40_-_06_'0_0'_____________ Page 5 of 13 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log 2. Appendix B: Field Measurement Data 3. Appendix C: SEM Maps 4. Appendix D: Cover Integrity Descriptions Page 6 of 13 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Emma Leeds Archival Record Location: Autumn Hills Digital Media Log DIGITAL IMAGE LOG: Image Number 1 2 3 4 5 6 7 8 9 10 11 File Name IMG_0799.JPG IMG_0800.JPG IMG_0801.JPG IMG_0802.JPG IMG_0803.JPG IMG_0804.JPG IMG_0805.JPG IMG_0806.JPG IMG_0807.JPG IMG_0808.JPG IMG_0809.JPG 12 IMG_0810.JPG 13 IMG_0812.JPG 14 IMG_0813.JPG 15 IMG_0816.JPG 16 IMG_0817.JPG 17 IMG_0818.JPG 18 IMG_0819.JPG 19 IMG_0820.JPG 20 IMG_0821.JPG 21 IMG_0822.JPG 22 IMG_0823.JPG 23 IMG_0824.JPG 24 IMG_0825.JPG 25 RIMG0001.JPG 26 RIMG0002.JPG 27 RIMG0003.JPG 28 RIMG0004.JPG 29 RIMG0005.JPG 30 RIMG0006.JPG 31 RIMG0007.JPG 32 RIMG0008.JPG 33 RIMG0009.JPG 34 RIMG0010.JPG 35 RIMG0011.JPG Date and Time 9/13/2024 9:39 9/13/2024 9:40 9/13/2024 9:40 9/13/2024 9:59 9/13/2024 10:00 9/13/2024 10:00 9/13/2024 10:00 9/13/2024 10:22 9/13/2024 10:22 9/13/2024 10:29 9/13/2024 10:29 9/13/2024 11:57 9/13/2024 12:42 9/13/2024 12:45 9/13/2024 12:52 9/13/2024 12:55 9/13/2024 12:57 9/13/2024 13:02 9/13/2024 13:06 9/13/2024 13:11 9/13/2024 13:15 9/13/2024 13:19 9/13/2024 13:20 9/13/2024 13:27 9/13/2024 10:40 9/13/2024 10:44 9/13/2024 10:44 9/13/2024 11:20 9/13/2024 11:24 9/13/2024 11:27 9/13/2024 11:32 9/13/2024 11:32 9/13/2024 11:38 9/13/2024 11:40 9/13/2024 11:46 Description of Image Cover Integrity Monitoring SOP Cover Integrity Monitoring SOP Cover Integrity Monitoring SOP Flare control panel Flare indicator lights Flare and blower Flare and blower Location of exceedance J1 Location of exceedance J1 Location of exceedance K1 Location of exceedance K1 Part of the area where WM prevented EPA from conducting SEM for "safety" reasons, claiming it was active Location of exceedance K8 Location of exceedance J10 Location of exceedance J11 Location of exceedance K9 Location of exceedance J12 Location of exceedance K10 Location of exceedance K11 Location of exceedance K12 Location of exceedance J13 Location of exceedance K13 Location of exceedance K14 Location of exceedance J14 Horizontal collector East slope of landfill - active filling area Passive flare, no longer operating Location of exceedance J2 Location of exceedance J3 Location of exceedance K2 Location of exceedance J4 Location of exceedance J4 Location of exceedance J6 Location of exceedance J5 Location of exceedance K3 Page 7 of 13 36 RIMG0012.JPG 37 RIMG0013.JPG 38 RIMG0014.JPG 39 RIMG0015.JPG 40 RIMG0016.JPG 41 RIMG0017.JPG 42 RIMG0018.JPG 43 RIMG0019.JPG 44 RIMG0020.JPG 45 RIMG0021.JPG 46 RIMG0022.JPG 47 RIMG0023.JPG Video Number 1 File Name MVI_0811.MP4 2 MVI_0814.MP4 3 MVI_0815.MP4 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 9/13/2024 11:50 9/13/2024 11:52 9/13/2024 11:53 9/13/2024 12:07 9/13/2024 12:08 9/13/2024 12:09 9/13/2024 12:12 9/13/2024 12:14 9/13/2024 12:20 9/13/2024 12:21 9/13/2024 12:26 9/13/2024 12:32 Location of exceedance K4 Part of the area where WM prevented EPA from conducting SEM for "safety" reasons, claiming it was active Marker pipe on leaking 8,000 ppm methane Location of exceedance K5 Location of exceedance K5 Location of exceedance J7 Tall vegetation/shrubery bordering "active" area where WM prevented EPA from performing SEM Location of exceedance J8 Location of exceedance J9 Marker pipe leaking 10,000 ppm methane Location of exceedance K6 Location of exceedance K7 Date and Time 9/13/2024 11:57 9/13/2024 12:45 9/13/2024 12:45 Description of Video Video of a portion of area claimed as "active face" by WM where EPA was prevented from monitoring, including at the extraction well. Vegetation throughout, including tall grass on storage piles. Solidification operations on "active face" Solidification operations on southernmost portion of top plateau of landfill, then videos pans north to remainder of area with Page 8 of 13 APPENDIX B: FIELD MEASUREMENT DATA Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 ID K1 K2 K3 K4 K5 K6 K6.5 K7 K8 K9 K10 K11 K12 K13 K14.5 K14 J1 J2 J3 J4 Irwin reading (ppm CH4) 2,863 941 821 2,792 2,342 713 897 1,398 1,363 1,026 9,746 1,146 5,711 2,693 2,621 13,641 1,222 1,239 826 530 Confirmation TVA reading (ppm CH4) 2,038 715 821 739 1,910 11,000 3,000 1,500 1,100 5,200 1,400 1,400 2,500 3,100 27,000 1,037 1,140 30,000 651 Description Large cracks in landfill surface Dead area in vegetation, far from any wells Deep erosion gully in otherwise grassy area GW-130 GW-169 and 10 ft surrounding eroded area Crack in surface Eroded area Penetration - electrical box Small spot of distressed vegetation Dead vegetation in grassy area Patchy grass coverage, no close wells Large area of distressed vegetation Hole in large area of distressed vegetation Hole in area with sparse grass coverage Distressed vegetation Multiple holes in a distressed vegetation area AHHL0044. Nearby ~12" diameter hole also >500ppm Dead patch in vegetation north of GW9R Distressed vegetation south of GW9R Deep erosion rills in clay surface Date/Time (ET) 9/13/2024 10:30 9/13/2024 11:28 9/13/2024 11:47 9/13/2024 11:51 9/13/2024 12:09 9/13/2024 12:22 9/13/2024 12:28 9/13/2024 12:35 9/13/2024 12:41 9/13/2024 12:54 9/13/2024 13:02 9/13/2024 13:07 9/13/2024 13:10 9/13/2024 13:20 9/13/2024 13:21 9/13/2024 13:23 9/13/2024 10:15 9/13/2024 11:22 9/13/2024 11:24 9/13/2024 11:34 LAT WGS84 42.776695 42.780125 42.779268 42.7792 42.77864 42.778265 42.778275 42.777875 42.777524 42.776238 42.775886 42.775764 42.775703 42.775498 42.775557 42.775551 42.777276 42.779949 42.779845 42.77934 LON WGS84 85.919139 85.917058 85.917578 85.917658 85.918375 85.918461 85.919092 85.918967 85.918807 85.919269 85.919286 85.919303 85.919382 85.919435 85.919346 85.919277 85.920135 85.917752 85.917711 85.917785 Page 9 of 13 J5 910 J6 1,276 J7 688 J8 865 J9 644 J10 195,282 J11 701 J12 21,835 J13 3,366 J14 521 800 1,931 776 1,011 1,312 22,000 943 7,500 4,500 4,000 Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 Gully in distressed vegetation area GW-136 Eroded patch within vegetation Cracked surface within vegetation Distressed vegetation GW-116 Cracks in grassy area Crack in area with patchy grass coverage GW-67 Distressed vegetation patch in grassy area 9/13/2024 11:38 9/13/2024 11:39 9/13/2024 12:10 9/13/2024 12:14 9/13/2024 12:38 9/13/2024 12:45 9/13/2024 12:53 9/13/2024 12:59 9/13/2024 13:11 9/13/2024 13:26 42.779275 42.779315 42.778578 42.778489 42.777408 42.776975 42.776029 42.775587 42.775515 42.774939 85.917837 85.917647 85.918457 85.918473 85.918495 85.918498 85.918829 85.918801 85.917424 85.918631 Calibration Data and Instrument Information IRwin 1 (S/N: 92004352) Calibration at 10:00 AM Measurement Reading for 503.1 ppm gas #1 493 #2 490 #3 494 Response Time 1 2 2 IRwin 2 (S/N: 92004350) Calibration at 10:00 AM Measurement Reading for 503.1 ppm gas #1 489 #2 489 #3 487 Response Time 1 2 3 TVA Bump Check Post Calibration at 9:45 AM TVA Reading for 550 ppm gas Reading for 1960 ppm gas Reading for 10000 ppm gas TVA # B39303 541 1961 9900 TVA # B39302 522 1920 9720 Page 10 of 13 Bump Check after SEM at 2:03 PM: Instrument Reading for 503.1 ppm gas Inficon IRwin #1 460 (S/N:92004352) Inficon IRwin #2 460 (S/N:92004350) Background Concentrations: Upwind Downwind 0 ppm 0.8 ppm Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 Page 11 of 13 APPENDIX C: SEM EXCEEDANCE MAP Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 Map of EPA and EGLE SEM Exceedances and Leaking Marker Pipes Page 12 of 13 APPENDIX D: COVER INTEGRITY DESCRIPTIONS Facility Name: WM Autumn Hills Landfill Facility Location: 700 56th Avenue, Zeeland, MI Date of Inspection: September 13, 2024 Number Description 1 Large cracks in landfill surface 2 Small spot of distressed vegetation 3 Cracks in grassy area 4 Dead vegetation in grassy area 5 Crack in area with patchy grass coverage 6 Patchy grass coverage, no close wells 7 Large area of distressed vegetation 8 Hole in large area of distressed vegetation 9 Hole in area with sparse grass coverage 10 Distressed vegetation 11 Multiple holes in a distressed vegetation area 12 Distressed vegetation patch in grassy area 13 Dead patch in vegetation north of GW9R 14 Distressed vegetation south of GW9R 15 Dead area in vegetation, far from any wells 16 Deep erosion rills in clay surface 17 Gully in distressed vegetation area 18 Marker pipe on leaking 8,000 ppm methane 19 Deep erosion gully in otherwise grassy area 20 Eroded area 21 Eroded patch within vegetation 22 Cracked surface within vegetation 23 Distressed vegetation 24 Marker pipe leaking 10,000 ppm methane 25 Crack in surface Image Number (s) 10, 11 13 15 16 17 18 19 20 22 Location of exceedance K14.5 23 24 28 29 30 31, 32 34 38 35 39, 40 41 43 44 45 46 Latitude Longitude 42.776695 -85.919139 42.777524 42.776029 42.776238 42.775587 42.775886 42.775764 42.775703 42.775498 -85.918807 -85.918829 -85.919269 -85.918801 -85.919286 -85.919303 -85.919382 -85.919435 42.775557 -85.919346 42.775551 42.774939 42.779949 42.779845 42.780125 42.77934 42.779275 -85.919277 -85.918631 -85.917752 -85.917711 -85.917058 -85.917785 -85.917837 42.779268 42.77864 42.778578 42.778489 42.777408 -85.917578 -85.918375 -85.918457 -85.918473 -85.918495 42.778265 -85.918461 Page 13 of 13