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Participating Personnel: Report Prepared by: Approved by: Leak Detection and Repair (LDAR) Inspection Report Ocean County Landfill 2498 NJ-70 Manchester Township, NJ 08759 AIRS ID: NJ0000003402978340 Inspection Date(s): August 13-14, 2024 US Environmental Protection Agency Omer Sohail, PE, Environmental Engineer Joesph Cardile, Engineer Phillip Ritz, Environmental Scientist Omer Sohail, PE Environmental Engineer Monitoring and Assessment Branch Carol Lynes, Chief Monitoring and Assessment Branch LDAR Inspection of Ocean County Landfill, Manchester, NJ Table of Contents: Leak Detection and Repair Report Introduction Management System Review Technical System Audit Compliance Monitoring Follow-Up Tables 1 LDAR Monitoring Data Appendices 1 Inspection Attendance Sheet 2 Tetra Tech Follow Up Letter Page 2 of 5 1-4 3 3 3 4 4 LSASD/MAB/QATSS AIRS ID: NJ0000003402978 Ocean County Landfill Manchester, NJ LDAR Inspection of Ocean County Landfill, Manchester, NJ Page 3 of 5 Inspection Date: August 13-14, 2024 Introduction: The Ocean County Landfill in Manchester, NJ is owned and operated by the Ocean County Landfill Corporation. The landfill is divided into separate sections with the following designations moving East to West: Cell 8 (eastern portion), Cell 7, Valley Fill (Active Face), Cell 6 (Solar Panel Area), Cell 3 and 9 (West Area, Old Waste) and Cell 1A (Future Phase 1, 2, and 3). The Ocean County Landfill is subject to NSPS Subpart XXX, 40 CFR 60.765 (c) and (d), and 40 CFR 60, Appendix A, Method 21 which requires the landfill to develop and implement a surface monitoring plan in which testing is conducted around the perimeter with a pattern that traverses the landfill at 30-meter intervals. Ocean County Landfill Corporation owns and operates the Gas Collection and Control System (GCCS) system onsite and maintains the horizontal wells. Tetra Tech (Cornerstone Environmental Group, LLC) conducts the Surface Emissions Monitoring. Management System Review: Objective: A management system review consists of an evaluation of the facility's current 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 previous reports, monitoring data, monitoring runs, component leak histories, leak repair procedures, calibration gas certificates of analysis, calibration logs, calibration precision testing, and calibration response time testing. Observations: Ocean County Landfill Corporation's SEM Contractor, Tetra Tech performs all surface emissions monitoring quarterly on the landfill. Any instrument reading greater than 500 ppm is considered an exceedance. If an exceedance is found by Tetra Tech, Marty Ryan and Rocky Crawford are immediately notified to remedy the leak. Ocean County Landfill Corporation is responsible for cover maintenance and will add dirt or clay to the surface if necessary. According to Ocean County Landfill Corp, re-monitoring is performed by Tetra Tech within 10 days. If the area passes re-monitoring, follow-up monitoring is performed in 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. LSASD/MAB/QATSS AIRS ID: NJ0000003402978 Ocean County Landfill Manchester, NJ Page 4 of 5 Omer Sohail reviewed the Semi Annual NSPS and SSM reports from January 2022 through January 2024, which include all quarterly surface monitoring conducted during those periods. All reports were found to be satisfactory. 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: Ocean County Landfill Corporation's surface emissions monitoring contractor, Tetra Tech, was not present during EPA's inspection. Ocean County Landfill Corporation did not have any surface emissions monitoring equipment on site; therefore, there are no observations to report. 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 in Table 1 of this report. Observations: Side by side surface monitoring could not be conducted as Tetra Tech was not present during EPA's inspection. EPA continued the inspection using a TVA 2020 with handheld analyzer. All results were relayed verbally in the field to Ocean County Landfill Corporations Environmental Compliance Specialist Marc Cusanelli and Plant Manager Rocky Crawford. Monitoring results were also relayed to Marty Ryan during the closing conference. Monitoring results are included in Table 1 of this report. Calibration of the TVA2020 was completed in the field prior to starting the surface emissions monitoring. The following calibration gasses 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 Table 1. A total of 52 points were monitored over the two-day period. Any reading above 500 ppm is considered a leak (60.755(c)(4)). As shown in Table 1, EPA detected 9 leaks, which equates to a leak rate of 17%. A majority of the leaks found were located on the base of the wells or header pipe. It should be noted that five (5) of the leaks were detected in the area where the landfill liner had recently been pulled back to accommodate additional landfill material at the LSASD/MAB/QATSS AIRS ID: NJ0000003402978 Ocean County Landfill Manchester, NJ Page 5 of 5 edge of Cell 7 and the Valley Fill Area. Upon conversation with Ocean County Landfill Corporation, they notified EPA that this area was pulled back to ensure proper drainage and will be corrected in the coming week. Aside from the leaks, EPA did not visibly see any areas of concern during the inspection. Region 2 inspectors used GIS Map Pro on iPhone 13 to record the coordinates of each point monitored at Ocean County Landfill. Coordinates for each point monitored can be found in Table 1. Follow-Up: At the closing conference held on August 14, 2024, Omer Sohail reviewed all the findings of the inspection with Marty Ryan, Marc Cusanelli, Lawrence Kiesel and Rocky Crawford. On August 15,, 2024, Phillip Ritz forwarded Marty Ryan the requested exceedances table with all exceedances locations and requested follow-up repair and monitoring data for all leaks found during the inspection. Following the inspection, on August 23, 2024, Marty Ryan notified EPA that all leaks had been remedied. All results from the re-monitoring were less than 500 ppm. On September 25th, 2024, Magda Mendola from Tetra Tech notified EPA that all results from the 30-day remonitoring were less than 500 ppm. The Tetra Tech Follow Up letter has been included as Appendix 2. LSASD/MAB/QATSS AIRS ID: NJ0000003402978 Ocean County Landfill Manchester, NJ Name Omer Sohail Phil Ritz Joseph Cardile Martin Ryan Marc Cusanelli Lawrence Kiesel Rocky Crawford Role/ Company Inspector, EPA, LSASD R2 Inspector, EPA, ACB R2 Inspector, EPA, ACB R2 Ocean County Landfill Corporation Ocean County Landfill Corporation Ocean County Landfill Corporation Ocean County Landfill Corporation Ocean County Landfill 2498 NJ-70, Manchester Township, NJ 08759 USEPA Inspection Attendance Sheet (August 13-14, 2024) Phone Number 732-321-6785 212-637-4064 212-637-4054 732-657-5100 732-657-5100 732-614-5107 732-735-8969 Email Address sohail.omer@epa.gov ritz.phillip@epa.gov cardile.joseph@epa.gov mryan@cjhesse.com mcusanelli@cjhesse.com lkiesel@cjhesse.com rockyc@cjhesse.com Attended Opening Attended Closing Conference Conference Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Ocean County Landfill 2498 NJ-70, Manchester Township, NJ 08759 Date of Inspection: August 13-14, 2024 Weather: August 13 - Partly Cloudy, High of 83 August 14 -Partly Cloudy, High 87 Sample ID Upwind Downwind VAULT 717 VAULT 719 VAULT 718 VAULT 716 VAULT 714 VAULT 745 CO 720 RISER BASE RISER BASE 721 RISER BASE 722 RISER BASE 723 RISER BASE 724 VAULT 709 RISER BASE NO LABEL VAULT 702 RISER BASE NO LABEL VAULT 804 VAULT 813 VAULT 703 VAULT 705 VAULT 708 RISER BASE 727 RISER BASE 728 RISER BASE 729 GROUND CRACK GROUND CRACK VAULT 505 VAULT 504 VAULT 511 VAULT 512 VAULT 513 VAULT 917 VAULT 916 VAULT 914 VAULT 908 VAULT 910 FLANGE/PIPE FLANGE/PIPE OPPOSITE CLAY PILE FLANGE/PIPE - BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE Concentration (ppm) 1.0 1.8 107.0 75.0 22.5 62.4 71.0 55.0 984.0 6,000.0 3400 7.5 5,250.0 2,900.0 0.8 16.1 0.8 0.0 0.0 1.2 1.8 0.9 0.2 1,720.0 10,000.0 17,000.0 9,500.0 65,000.0 2.0 2.3 2.1 2.3 2.0 0.2 0.1 0.5 0.2 0.5 1.0 5.2 2.1 1.5 1.4 0.0 0.0 Location of Sample Ambient Ambient Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Approximate GPS Location 40.0175, 74.24245 40.01225, 74.24245 40.01656, 74.24578 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.011645, 74.24460 40.011645, 74.24460 40.01634, 74.24560 40.01634, 74.24560 40.011607, 74.24603 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01678, 74.24530 40.01667, 74.24599 40.01661, 74.24652 40.01663, 74.24653 40.01662, 74.24699 40.01662, 74.24699 40.01662, 74.24699 40.01993, 74.24967 40.01993, 74.24967 40.01993, 74.24967 40.01993, 74.24967 40.02321, 74.25814 40.02321, 74.25814 40.02321, 74.25814 40.02321, 74.25814 40.02555, 74.26036 40.02555, 74.26036 Repaired 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 Page 1 of 2 Notes Active Face Active Face Active Face Active Face Active Face, Verified by IR United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Ocean County Landfill 2498 NJ-70, Manchester Township, NJ 08759 Date of Inspection: August 13-14, 2024 Weather: August 13 - Partly Cloudy, High of 83 August 14 -Partly Cloudy, High 87 Sample ID MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE FLANGE/PIPE BY SCALE HOUSE LOW OPEN MAN HOLE BY SCALE HOUSE Concentration (ppm) 1.7 1690-2280 0.0 1.7 0.0 Location of Sample Base 1.5' Above Ground Base Base Base Approximate GPS Location 40.02555, 74.24452 40.02023, 74.24452 40.02023, 74.24452 40.02023, 74.24452 Repaired 40.02023, 74.24452 MANHOLE NEAR SCALE 1.2 Base 40.02023, 74.24452 MANHOLE NEAR SCALE 1.8 Base 40.02023, 74.24452 Notes Leak detected about 1.5' above ground coming from the manhole cover Page 2 of 2 September 25, 2024 Mr. Philip A. Ritz Environmental Protection Agency 209 Broadway 21st Floor New York, NY 10007-1866 Re: EPA Site Inspection - August 13 and 14, 2024 Ocean County Landfill Dear Mr. Ritz: On August 13 and August 14, 2024, landfill gas (LFG) surface emissions monitoring (i.e., for methane) was performed at the Ocean County Landfill (OCLF). During this 2-day event, present at the site were representatives of US Environmental Protection Agency, Region II (EPA) and OCLF. This letter report provides a summary of the field activities, observations, findings, performed during this 2-day period, as well as follow-up activities performed 10 days after, on August 23, 2024, and 30 days after the initial event, on September 13, 2024. During their 2-day inspection, EPA personnel conducted monitoring activities, interviewed OCLF personnel, and familiarized themselves with the site. On Tuesday, August 13, 2024, EPA identified five (5) locations within Cell 7 near the Valley Fill as areas of concern (see table below). On Wednesday, August 14, 2024, EPA identified one (1) additional location, a manhole near the scale house, as an area of concern. Subsequent to EPA's inspection, gas vacuum was increased in the areas of the penetrations and manholes. Additionally, repairs were made to the HDPE pipe boot at the penetrations. On August 23, 2024, a field technician of Cornerstone Environmental Group, LLC - a Tetra Tech Company (Tetra Tech), re-monitored the six (6) locations where the exceedances were initially recorded by the EPA. Readings taken from all six (6) locations were well below 500 ppm. On September 13, 2024, 30 days after the initial Inspection, a Tetra Tech field technician, re-monitored the six (6) locations. Readings taken from all six (6) locations were well below 500 ppm. Tetra Tech 100 Crystal Run Road, Suite 101, Middletown, NY 10941 Tel +1.877.294.9070 Fax +1.877.845.1456 | tetratech.com Mr. Philip A. Ritz September 25, 2024 Tetra Tech's results are as follows: EPA Location OCLF Location CO 720 P7-20 (Riser Top) EPA Readings August 13 984 ppm Corrective Action Increase vacuum/repair pipe boot Tetra Tech Readings August 23 -2.3 ppm Tetra Tech Readings September 13 -4.3 ppm Riser Base 720 P7-20 (Riser Base) 6,000 ppm Increase vacuum/repair pipe boot -1.9 ppm -4.1 ppm Riser Base 721 P7-21 (Riser Base) 3,400 ppm Increase vacuum/repair pipe boot 2.5 ppm -4.2 ppm Riser Base 723 P7-23 (Riser Base) 5,250 ppm Increase vacuum/repair pipe boot -2.3 ppm -4.3 ppm Riser Base 724 P7-24 (Riser Base) 2,900 ppm Increase vacuum/repair pipe boot -2.5 ppm -4.2 ppm Manhole by Scale House 1,690 to 2,280 ppm* Increase vacuum 3.5 ppm -3.4 ppm * Location identified on August 14, 2024. I trust this satisfies the EPA's requirements with regards to this issue, however, should you require additional information please feel free to call our office at 845-695-0200. Sincerely, CORNERSTONE ENVIRONMENTAL GROUP, LLC - A TETRA TECH COMPANY Magdalena Mendola Senior Project Manager cc: J. Cardile - EPA O. Sohail - EPA M. Ryan - OCLF M. Cusanelli - OCLF P. Shaw - Tetra Tech K. Vorsa - Tetra Tech Daryl O'Dell, P.E. Client Manager 2 Tetra Tech 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: EPA Asst. Inspector: CAA Inspection Report 8/13-14/2024 Ocean County Landfill 2498 Route 70, Manchester, NJ 08759 NJ0000003401555412 Martin Ryan mryan@cjhesse.com Phillip Ritz, Environmental Engineer, ECAD-ACB, 212-637-4054 Joseph Cardile, Environmental Engineer, ECAD-ACB, 212-637-4054 Omer Sohail, Environmental Engineer, LSASD -MAB, 732-321-4461 I. Facility Background: Ocean County Landfill in Manchester, New Jersey is a privately-owned operation that opened in 1972. The facility is located 185 feet above sea level and processes about 600,000 tons of waste per year, including debris from Hurricane Sandy recovery efforts. The landfill operating hours are Monday to Friday: 7:00 AM - 3:30 PM and Saturday: 7:00 AM - 12:00 PM. The landfill has about 50 employees. The waste footprint at the facility was 13 million megagrams in the statement of basis for the draft Title V permit. At present, the landfill is permitted for waste, including, but not limited to, Cells 1B/2B, 4, 5, 6, 7, 8 and 9. This facility just completed a reclamation project which involved removing waste from a large unlined cell that was filled with municipal solid waste by the previous owner of the landfill. At current and projected filling rates, it is anticipated that the landfill continues accepting waste for ten years or more. II. Pertinent Regulatory Requirements Ocean County Landfill is subject to the new Federal Plan Requirements for Municipal Solid Waste (MSW) 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). Ocean County Landfill became subject to the Federal Plan in June 2021 and is no longer subject to the Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification on or After May 30, 1991, but Before July 18, 2014 (NSPS, Subpart WWW). III. List of Attendees Martin Ryan, Ocean County Landfill Corporation, Vice President at The Hesse Companies, 732-657-5100, Ocean County Landfill - NJ0000003401555412 1 8/13-14/2024 mryan@cjhesse.com Marc Cusanelli, Ocean County Landfill Corporation, 732-657-5100, mcusanelli@cjhesse.com Lawrence Kiesel, Ocean County Landfill Corporation, Vice President of Construction, 732-614-5107, lkiesel@cjhesse.com Rocky Crawford, Ocean County Landfill Corporation, Plant Operations, 732-735-8969, rockyc@cjhesse.com Phil Ritz, Inspector, EPA, 212-637-4064, ritz.phillip@epa.gov Joseph Cardile, Inspector, EPA, 212-637-4054, cardile.joseph@epa.gov Omer Sohail, Inspector, EPA, 732-321-6785, sohail.omer@epa.gov IV. Pre-Inspection Notification In August 2024, Inspector Ritz contacted Ocean County Landfill, by telephone to confirm that EPA planned to conduct a Clean Air Act inspection of Ocean County Landfill on August 13-14, 2024 (weather permitting), that would focus primarily on methane leak detection and repair (LDAR) requirements applicable to the landfill. Inspector Ritz further explained that EPA was planning to conduct its own surface emission monitoring (SEM) during its inspection of the landfill using appropriate SEM equipment. Finally, Inspector Ritz requested that Ocean County Landfill, at the time of EPA's inspection, have available its staff and/or contractor who conducted SEM at the landfill because EPA would like to observe Ocean County staff and/or its contractor perform routine calibration of their monitoring equipment and conduct comparative SEM alongside the EPA inspectors. V. Entrance Conference On August 13, 2024, EPA Inspectors Phillip Ritz, Joseph Cardile, and Omer Sohail ("EPA Inspectors") arrived at Ocean County Landfill's administrative offices in Manchester, NJ at approximately 10:00 AM. EPA Inspectors showed their credentials and were directed to the facility's administrative conference room. 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 records review of the facility's leak detection data. In addition, EPA Inspectors planned to also observe landfill 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 Toxic Vapor Analyzer (TVA) during the inspection. The facility representatives then explained that the staff that normally perform monitoring equipment calibrations and conduct routine LDAR/SEM of this landfill were not available and would not participate on this inspection. In response, the EPA inspectors explained that since Ocean County Landfill, would not be conducting comparative LDAR/SEM as requested by Ocean County Landfill - NJ0000003401555412 2 8/13-14/2024 EPA, then any methane leaks identified by the EPA Inspectors would be required to be repaired by landfill staff as if those leaks had been discovered during the routine quarterly SEM conducted by the landfill. Prior to touring the landfill, EPA Inspectors discussed and reviewed the applicable compliance requirements of 40 CFR Part 62, Subpart OOO and 40 CFR, Subpart AAAA. This included discussions of the standards for the control of landfill gas (LFG) emissions from the landfill including applicable requirements for gas collection and control system (GCCS), operational standards, and recordkeeping. Landfill representatives explained that the landfill's GCCS is equipped to capture and flare all of the LFG generated by the landfill. The landfill currently generates approximately 6,600 standard cubic feet per minute (scfm) of landfill gas. The flaring system consists of two (2) enclosed flares each capable of handling 3,000 scfm of LFG and one (1) candle stick flare capable of handling 600 scfm of LFG. The facility plans to upgrade and replace the candle stick with a new flare capable of handling an additional 3,000 scfm of LFG. The landfill primarily utilizes horizontal gas collection wells that are contained in underground vaults. Besides the landfill's GCCS and flaring system, the landfill utilizes environmental controls to manage and control hydrogen sulfide (H2S) and dust emissions. The H2S controls consists of an activated H2S removal systems in place with iron sponges for H2S mitigation. Dust Control measures primarily consist of water spraying. Groundwater monitoring is conducted twice annually. Landfill representatives explained how the landfill's expansion and improvement plans include new geomembrane installation to be installed over 40 acres, which will significantly improve leachate control. Also, an elevation increase for new waste capacity has been approved for implementation in the 2036-2037 timeframe. Finally, a $75 million thermal screening or mining project is ongoing to reclaim waste deposited years ago in another unlined cell by the previous owner of the landfill. VI. Summary of Observations/Landfill Tour At approximately 11:30 AM on August 13, 2024, the EPA Inspectors along with representatives from Ocean County Landfill began conducting SEM on the landfill. The EPA Inspectors proceeded to walk the surface of the landfill conducting SEM using EPA's TVA. Prior to starting SEM, the calibration of the TVA was completed in the field by the EPA Inspectors. The following calibration gasses were used in the daily calibration: Zero Air, Methane at various concentrations, and Methane at 1% volume. Background concentrations were determined both upwind and downwind of the landfill. Ocean County Landfill - NJ0000003401555412 3 8/13-14/2024 EPA Inspectors surveyed various sections of the landfill to detect potential methane emissions. EPA monitored several surface points at random and all results were relayed verbally in the field to representatives from Ocean County Landfill and written down. Any location where EPA identified a methane concentration above 500 ppm was considered a leak and noted as an area of concern. Overall, EPA Inspectors completed SEM over a portion of the landfill's surface area and at numerous surface penetrations during a two-day timeframe. EPA Inspectors identified ten (10) methane leak events in excess of 500 ppm out of approximately 50 points sampled on the landfill. This equates to a methane leak hit rate in excess of 20%. A comprehensive list, which includes the name, location, and the methane concentration measured at each sampled point, is shown in Table 1 of this report titled "EPA Exceedance Report". However, many of the leaks were identified in areas of the landfill close to the "active face" and appeared to be coming from areas where waste had been deposited for less than five years. During EPA's SEM effort, EPA Inspectors observed the ongoing landfill mining activity being conducted by Ocean County Landfill to eliminate the unlined landfill area, which is crucial for groundwater protection. The EPA Inspectors observed the current excavation and screening project which involves reclaiming of approximately four (4) million cubic yards of old solid waste material from a 60-acre parcel. The reclaimed waste is being deposited in new lined cells. The overall reclamation effort will result in an additional six (6) million cubic yards of new landfill capacity along with the recovery of two (2) million cubic yards of soil that will be used as daily cover on the open face of the landfill. VII. Closing Conference: At the closing conference, EPA Inspectors explained that EPA does not provide compliance determinations on its inspections and how all CAA compliance determinations required EPA Supervisory review/approval. However, EPA Inspectors discussed the number of methane leak events (i.e., methane leaks in excess of 500 ppm) they had identified and documented while conducting their own SEM. 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 Ocean County Landfill via email within the next few days. It was also agreed at the closing meeting that the required timeframe to repair these leaks would start upon Ocean County Landfill's receipt of EPA's leak results. Finally, the EPA Inspectors thanked Ocean County Landfill representatives for their cooperation and availability during its two-day inspection of the landfill. This concluded the EPA inspection and the EPA Inspectors left the landfill at approximately 4:00 PM on August 14, 2024. Ocean County Landfill - NJ0000003401555412 4 8/13-14/2024 Table 1: EPA Exceedance Report: United States Environmental Protection Agency 2890 Woodbridge Avenue, Edison, NJ 08837 Monitoring and Assessment Branch Surface Emissions Monitoring - Leak Detection and Repair Ocean County Landfill 2498 NJ-70, Manchester Township, NJ 08759 Date of Inspection: August 13-14, 2024 Weather: August 13 - Partly Cloudy, High of 83 August 14 -Partly Cloudy, High 87 Sample ID Upwind Downwind VAULT 717 VAULT 719 VAULT 718 VAULT 716 VAULT 714 VAULT 745 CO 720 RISER BASE RISER BASE 721 RISER BASE 722 RISER BASE 723 RISER BASE 724 VAULT 709 RISER BASE NO LABEL VAULT 702 RISER BASE NO LABEL VAULT 804 VAULT 813 VAULT 703 VAULT 705 VAULT 708 RISER BASE 727 RISER BASE 728 RISER BASE 729 Concentration (ppm) 1.0 1.8 107.0 75.0 22.5 62.4 71.0 55.0 984.0 6,000.0 3400 7.5 5,250.0 2,900.0 0.8 16.1 0.8 0.0 0.0 1.2 1.8 0.9 0.2 1,720.0 10,000.0 17,000.0 Location of Sample Ambient Ambient Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Approximate GPS Location 40.0175, 74.24245 40.01225, 74.24245 40.01656, 74.24578 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.01625, 74.24661 40.011645, 74.24460 40.011645, 74.24460 40.01634, 74.24560 40.01634, 74.24560 40.011607, 74.24603 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01597, 74.24646 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01555, 74.24465 40.01678, 74.24530 40.01667, 74.24599 40.01661, 74.24652 Repaired Notes Active Face Active Face Active Face Ocean County Landfill - NJ0000003401555412 5 8/13-14/2024 GROUND CRACK GROUND CRACK VAULT 505 VAULT 504 VAULT 511 VAULT 512 VAULT 513 VAULT 917 VAULT 916 VAULT 914 VAULT 908 VAULT 910 FLANGE/PIPE FLANGE/PIPE OPPOSITE CLAY PILE FLANGE/PIPE - BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE MAN HOLE BY SCALE HOUSE FLANGE/PIPE BY SCALE HOUSE LOW OPEN MAN HOLE BY SCALE HOUSE MANHOLE NEAR SCALE MANHOLE NEAR SCALE 9,500.0 65,000.0 2.0 2.3 2.1 2.3 2.0 0.2 0.1 0.5 0.2 0.5 1.0 5.2 2.1 1.5 1.4 0.0 0.0 1.7 1690-2280 0.0 1.7 0.0 1.2 1.8 Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base Base 1.5' Above Ground Base Base Base Base Base 40.01663, 74.24653 40.01662, 74.24699 40.01662, 74.24699 40.01662, 74.24699 40.01993, 74.24967 40.01993, 74.24967 40.01993, 74.24967 40.01993, 74.24967 40.02321, 74.25814 40.02321, 74.25814 40.02321, 74.25814 40.02321, 74.25814 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.26036 40.02555, 74.24452 40.02023, 74.24452 40.02023, 74.24452 40.02023, 74.24452 40.02023, 74.24452 40.02023, 74.24452 40.02023, 74.24452 Active Face Active Face, Verified by IR Leak detected about 1.5' above ground coming from the manhole cover Ocean County Landfill - NJ0000003401555412 6 8/13-14/2024 Lead Inspector's Name: Phillip Ritz 10/23/2024 X Phillip Ritz Lead Inspector Signed by: PHILLIP RITZ Assisting Inspector's Name: Joseph Cardile 10/23/2024 X Phillip Ritz for Joseph Cardile Assisting Inspector Signed by: PHILLIP RITZ Supervisor's Name: Harish Patel 10/24/2024 X Harish Patel Su p e rvi so r Signed by: HARISH PATEL Ocean County Landfill - NJ0000003401555412 7 8/13-14/2024