Document e5v6EJaKqXx9anK2GjgrNB374

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Clark-Floyd Landfill, Borden, Indiana FROM: Kenneth Ruffatto, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 EPA Inspector(s): 1. Kenneth Ruffatto, Environmental Engineer 2. Ethan Chatfield, Environmental Engineer 3. Aileen Drum, Environmental Engineer 4. Giles Chickering, Environmental Engineer/Scientist Other Attendees: 1. Amy Rotert, Air Compliance Inspector, IDEM 2. Jeremiah Hunt, Air Compliance Inspector, IDEM 3. Matt Lee, President, CFL, LLC 4. Albert Masticola, Gas Technician, CFL, LLC Contact Email Address: Matt Lee -- mlee@clarkfloydlandfill.com Purpose of Inspection: Landfill Monitoring Inspection Facility Type: Municipal Solid Waste Landfill Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart XXX; 40 C.F.R. Part 63, Subpart AAAA; Title V Permit Arrival Time: 8:00 AM EST Departure Time: 3:30 PM EST 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: Provided CBI warning to facility The following information was obtained verbally from Mr. Lee and Mr. Masticola unless otherwise noted. Company Ownership: The landfill is jointly owned by Clark and Floyd counties in Indiana and is operated by CFL, LLC. Phil Kato operated the landfill prior to CFL taking over operation in 2004. Process Description: Clark-Floyd Landfill (CFL) is a municipal solid waste (MSW) landfill that began accepting waste in approximately 1971. The expected closure of the landfill is 2046 with the possibility of a horizontal expansion moving the closure to 2056. CFL is made up of an East and West hill with active faces on both. Construction and demolition waste is currently being disposed on the West hill, while MSW is being disposed on the East hill. A slurry wall was completed around the perimeter of CFL, and operations are expected to be moved primarily to the West hill. CFL has a RCRA Subtitle D liner and leachate is collected and stored in leachate storage tanks on the east side of the site. CFL does not currently perform any leachate recirculation but is permitted to do so. The gas collection and control system (GCCS) is composed of approximately 140 vertical gas extraction wells and a single Parnel candlestick flare for gas control. The flare is supplied by two blowers, with only one blower operating at a time. Prior the current expansion/reconstruction that began in 2024, there were 93 wells. Prior to the Parnel flare, installed in approximately 2016, there was a gas to energy system operated by Hoosier Energy at the site with a backup enclosed flare (did not include a variable speed motor), both now decommissioned. Page 2 of 13 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Staff Interview: CFL stated that they are currently undergoing a large construction project on the GCCS, including new header/lateral lines and gas wells. They are currently finishing Phase 3 of a seven-phase project. CFL stated that while they have approximately 140 gas wells, there are 10 new wells that are scheduled to be installed on the west side of the East hill. Tetra Tech AEG is responsible for well installations. The East hill also recently went through a gas system overhaul where header lines were moved from the middle of the landfill towards the outside to avoid filling operations. When installing new gas wells, CFL increased well diameter to 6" instead of 4" and have installed pneumatic pumps in approximately 10 wells with water issues. CFL staff stated that the pumps were installed due to water issues in wells on the south side of the East hill, indicating that many of the wells were potentially "watered in". CFL staff noted that while one blower to the open flare could provide approximately 1,260 standard cubic feet per minute (scfm) of landfill gas; a switch to the second blower causes a drop of 200+ scfm (i.e., flow rate of 1,000 scfm) of gas to the flare. The operating blower is rotated monthly to allow for equal wear-and-tear on each of the two blowers. CFL stated that there are plans for a potential renewable natural gas (RNG) facility to be installed on the north end of the landfill and that they are currently in negotiation over gas rights with the County. CFL is responsible for all SEM, gas monitoring probe, and wellhead monitoring at the landfill. CFL stated that their most recent SEM monitoring found approximately three SEM hits, though they have historically found up to 30 SEM hits in a single monitoring period. CFL also stated that they have not had gas migration issues at the landfill. The only closed portion of the landfill is a small 2-to-3-acre section called Cell 5. Otherwise, all other areas of the landfill are under interim cover, which is composed of 2 feet of soil in most areas but 4 to 5 feet in areas prone to erosion. Interim cover has been used since CFL is primarily adding waste vertically at this point rather than horizontally into new cells. CFL plans to put seed on the East hill in Spring 2025 to help prevent erosion. CFL staff stated that due to the use of river mud (i.e., silty) soil for cover, there has been a lot of difficulty controlling erosion. Closing Conference Follow-up Call: Since key site staff were not available during the time of the inspection, EPA agreed to a follow-up call with CFL for the closing conference. A call was conducted on November 25, 2024 at 11 AM CST, where a typical closing conference was conducted including sharing concerns, outlining next steps, and requesting documents. This was attended by CFL, LLC including Matt Lee (present during inspection); Robert Lee, President (not present during inspection); and Bruce Schmucker, Vice President of Engineering and Environmental Affairs (not present during inspection) and Tetra Tech and facility consultant Jessica Palmer, Senior Project Manager (not present during inspection). TOUR INFORMATION EPA Toured the Facility: Yes Page 3 of 13 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Data Collected and Observations: EPA first observed the Parnel open flare and recorded that it was operating at approximately 1,250 scfm and 15 inches of water column. The flare nameplate stated: Parnel Biogas Job # 16-155 DNL-101 ship date 8-15-2016. The Blower nameplates stated: Model # NT88103-03-GD, Order # 2161104 with Serial #s 2161104A and B. EPA conducted a partial SEM survey of the Landfill that centered around areas where visual observations may indicate elevated concentrations of landfill gas (e.g., distressed vegetation, cracks or seeps in cover, and cover penetrations). Kenneth Ruffatto, Ethan Chatfield, and Giles Chickering monitored the surface and confirmed each other's exceedances. Aileen Drum recorded readings, took pictures, and marked with flags each SEM hit location. EPA used three Elkin Irwin devices to perform EPA Reference Method 21 for the SEM. EPA inspectors detected and documented 50 points on the Landfill surface with concentrations of methane above 500 ppm. Some of the documented points involved areas where there were numerous exceedances, particularly in eroded areas, but only one point was recorded for each location. Of the 50 SEM hits found, 21 were found in areas of erosion, 27 were at the base of wellheads, and 2 were found near header seams. All SEM photos and locations/concentrations are documented in Appendices A and B, respectively, with visual maps shown in Appendix C. Cover integrity issues were noted over most of the non-vegetative slopes on the East hill during SEM including large erosion reels and exposed trash, with some locations having leachate breakouts. See Appendix A for photos. Additionally, elevated levels of landfill gas above background were seen over a large portion of the SEM path taken. See Appendix C for a concentration map of all continuous 10 second readings taken during SEM. EPA inspectors found three gas wells (i.e., 366R, 485, 507) where the flex hose was detached from the lateral line. The valves on the wellheads were not closed, and gas was determined to be passively venting from the flex hose. In all three cases, the Irwin was used to verify that it was landfill gas. See Appendix A for photos of the three wells (i.e., Image #s 51-52, 79-83). CFL staff reattached the three well hoses when EPA staff alerted them. EPA inspectors also noted at least one well for which the flex hose was still attached, but appeared to have a poor seal and was leaking landfill gas (as detected by the Irwin). During monitoring, CFL staff noted that numerous wells had water issues on the south side of the East hill which triggered CFL to install pneumatic pumps in the wells. CFL staff also stated during the inspection that they do not believe there is enough vacuum, which is why numerous wells may have SEM hits at the base. Photos: were taken during the inspection and are listed in Appendix A. Field Measurements: were taken as a part of SEM during the inspection and are listed in Appendix B with associated maps in Appendix C. Page 4 of 13 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 RECORDS REVIEW An overhead map of the facility was reviewed on-site. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: GCCS Design Plan--most recent GCCS As-Built--most recent Construction Plans for GCCS Improvements Semi-Annual Reports--last 3 reports Quarterly Surface Emission Monitoring Reports--last 3 quarters Monthly Gas Wellhead Monitoring--last 3 months Concerns: EPA had four areas of immediate concern after visiting the Landfill: 1) SEM - a high rate of SEM hits, above the historical average for the Landfill; 2) Cover - major erosion issues and exposed trash over a majority of the East hill seen during SEM with little vegetative cover; 3) Gas Collection - at least three vertical wells were found where the flex hose from the wellhead was detached from the lateral line and passively venting to the atmosphere, and leaking was found in gas components including wellhead connections and header/lateral welds; and 4) Gas Control - facility staff reported that the flare drops nearly 200 scfm when switching to Blower #2 (i.e., redundant blower). DIGITAL SIGNATURES Ruffatto, Digitally signed by Ruffatto, Kenneth Report Author: _K__e_n_n_e_t_h______0_7:4_0_:18_-_06_'0_0'____________ Date: 2024.12.02 Section Supervisor: NATHAN Digitally signed by NATHAN FRANK FRANK Date: 2024.12.04 10:52:12 -06'00' __________________________________ Page 5 of 13 APPENDICES 1. Appendix A: Digital Image Log 2. Appendix B: Field Measurement Data 3. Appendix C: Field Measurement Data Maps Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Page 6 of 13 APPENDIX A: DIGITAL IMAGE LOG Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Inspector Name: Kenneth Ruffatto and Ethan Chatfield Archival Record Location: ERC 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 25 26 27 28 29 30 31 32 33 34 35 File Name IMG_1706.JPG IMG_1707.JPG IMG_1708.JPG IMG_1709.JPG IMG_1710.JPG IMG_1711.JPG IMG_1712.JPG IMG_1713.JPG IMG_1714.JPG IMG_1715.JPG IMG_1716.JPG IMG_1717.JPG IMG_1718.JPG IMG_1719.JPG IMG_1720.JPG IMG_1721.JPG IMG_1722.JPG IMG_1723.JPG IMG_1724.JPG IMG_1725.JPG IMG_1726.JPG IMG_1727.JPG IMG_1728.JPG IMG_1729.JPG IMG_1730.JPG IMG_1731.JPG IMG_1732.JPG IMG_1733.JPG IMG_1734.JPG IMG_1735.JPG IMG_1736.JPG IMG_1737.JPG IMG_1738.JPG IMG_1739.JPG IMG_1740.JPG 36 IMG_1741.JPG Date and Time 11/13/2024 9:13 11/13/2024 9:15 11/13/2024 9:15 11/13/2024 9:15 11/13/2024 9:16 11/13/2024 9:17 11/13/2024 9:18 11/13/2024 9:26 11/13/2024 9:38 11/13/2024 9:38 11/13/2024 9:39 11/13/2024 9:39 11/13/2024 9:40 11/13/2024 9:40 11/13/2024 9:41 11/13/2024 9:43 11/13/2024 9:50 11/13/2024 9:50 11/13/2024 10:04 11/13/2024 10:04 11/13/2024 10:05 11/13/2024 10:05 11/13/2024 10:07 11/13/2024 10:08 11/13/2024 10:12 11/13/2024 10:15 11/13/2024 10:19 11/13/2024 10:29 11/13/2024 10:30 11/13/2024 10:31 11/13/2024 10:31 11/13/2024 10:31 11/13/2024 10:35 11/13/2024 10:36 11/13/2024 10:44 11/13/2024 10:50 Description of Image IRwin S/N 82 Probe Placement Calibration Gas Calibration Gas IRwin S/N 50 Probe Placement IRwin S/N 50 Probe Placement IRwin S/N 52 Probe Placement IRwin S/N 52 Probe Placement Landfill Site Map Flare Flare equipment Flare Flare control screen (unreadable due to glare) Flare control screen (unreadable due to glare) Flare control screen (unreadable due to glare) Backside of flare Hill opposite flare Exposed waste on hill (leachate?) Exposed waste on hill (leachate?) Exposed waste on hill Pooling liquid leading up hill Exposed waste on hill Erosion rills Erosion rills Erosion rills Exceedance G1 Exceedance K1 Exposed waste and erosion Exceedance G2 Exceedance E1 Erosion rills Exposed waste and erosion Exposed waste and erosion Exceedance G3 at well 308R Exposed waste and erosion Exposed waste Exceedance K2 at well 286 (Ken heard water and Albert confirmed the well is watered in) MAP ID (See App C) 2 1 3 4 5 7 Page 7 of 13 Image # 37 38 39 40 41 42 43 44 45 46 47 48 49 File Name IMG_1742.JPG IMG_1743.JPG IMG_1744.JPG IMG_1745.JPG IMG_1746.JPG IMG_1747.JPG IMG_1748.JPG IMG_1749.JPG IMG_1750.JPG IMG_1751.JPG IMG_1752.JPG IMG_1753.JPG IMG_1755.JPG 50 IMG_1756.JPG 51 IMG_1757.JPG 52 IMG_1760.JPG 53 IMG_1761.JPG 54 IMG_1762.JPG 55 IMG_1763.JPG 56 IMG_1764.JPG 57 IMG_1765.JPG 58 IMG_1766.JPG 59 IMG_1767.JPG 60 IMG_1768.JPG 61 IMG_1769.JPG 62 IMG_1770.JPG 63 IMG_1771.JPG 64 IMG_1772.JPG 65 IMG_1773.JPG 66 IMG_1774.JPG 67 IMG_1775.JPG 68 IMG_1776.JPG 69 IMG_1777.JPG 70 IMG_1778.JPG 71 IMG_1779.JPG 72 IMG_1780.JPG Date and Time 11/13/2024 10:51 11/13/2024 10:54 11/13/2024 10:55 11/13/2024 10:58 11/13/2024 10:58 11/13/2024 10:58 11/13/2024 10:59 11/13/2024 11:00 11/13/2024 11:00 11/13/2024 11:01 11/13/2024 11:05 11/13/2024 11:06 11/13/2024 11:08 11/13/2024 11:10 11/13/2024 11:19 11/13/2024 11:19 11/13/2024 11:25 11/13/2024 11:26 11/13/2024 11:27 11/13/2024 11:30 11/13/2024 11:30 11/13/2024 11:33 11/13/2024 11:34 11/13/2024 11:37 11/13/2024 11:39 11/13/2024 11:42 11/13/2024 11:44 11/13/2024 11:45 11/13/2024 11:46 11/13/2024 11:47 11/13/2024 11:50 11/13/2024 11:54 11/13/2024 11:56 11/13/2024 12:01 11/13/2024 12:05 11/13/2024 12:10 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Description of Image Exposed waste and flagging mattress Exceedance E3 Exposed waste Exceedance K3 at well 326 Exposed waste Exposed waste Exposed waste and pile of foam Exposed leachate Exposed leachate Exposed waste Exceedance G4 at well 345 Exposed trash at well 346 Exceedance E4 at well 346 Unconfirmed exceedance E5 near erosion rill with exposed leachate Well 366R open venting with a leak of 65,000 ppm measured coming from detached pipe Well 366R open venting Erosion gullies with exposed waste Erosion gullies with exposed waste GCCS Piping above ground GCCS Piping above ground Exceedance K4 Exceedance E7 by deep erosion gully with flagging waste Exceedance E7 by deep erosion gully with flagging waste Exceedance E8 Exceedance E9 at well 387R Erosion and exposed waste Exceedance G5 at well 405 Exposed waste and erosion Erosion gullies Exposed waste Exceedance K5 at former well 426 (staff said well needs to be dug up and capped) Exceedance G6 at well 447R Exceedance K6 by erosion gullies Exceedance E10 at well 409 Exceedance E11 at well 429 Exceedance E12 MAP ID (See App C) 8 9 10 11 12 14 15 15 17 18 16 19 20 21 22 23 24 Page 8 of 13 Image # 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 File Name IMG_1781.JPG IMG_1782.JPG IMG_1783.JPG IMG_1784.JPG IMG_1785.JPG IMG_1786.JPG IMG_1787.JPG IMG_1788.JPG IMG_1789.JPG IMG_1790.JPG IMG_1791.JPG IMG_1793.JPG IMG_1794.JPG IMG_1795.JPG IMG_1796.JPG IMG_1797.JPG IMG_1798.JPG IMG_1799.JPG 91 IMG_1800.JPG 92 IMG_1801.JPG 93 IMG_1802.JPG 94 IMG_1803.JPG 95 IMG_1804.JPG 96 IMG_1805.JPG 97 IMG_1806.JPG 98 IMG_1807.JPG 99 IMG_1808.JPG 100 IMG_1809.JPG 101 IMG_1810.JPG 102 IMG_1811.JPG 103 IMG_1812.JPG 104 IMG_1813.JPG 105 IMG_1814.JPG 106 IMG_1815.JPG 107 IMG_1816.JPG Date and Time 11/13/2024 12:14 11/13/2024 12:16 11/13/2024 12:18 11/13/2024 12:21 11/13/2024 12:27 11/13/2024 12:33 11/13/2024 12:36 11/13/2024 12:36 11/13/2024 12:36 11/13/2024 12:38 11/13/2024 12:38 11/13/2024 12:42 11/13/2024 12:46 11/13/2024 12:46 11/13/2024 12:50 11/13/2024 12:58 11/13/2024 13:01 11/13/2024 13:06 11/13/2024 13:07 11/13/2024 13:12 11/13/2024 13:15 11/13/2024 13:28 11/13/2024 13:33 11/13/2024 13:34 11/13/2024 13:36 11/13/2024 13:37 11/13/2024 13:40 11/13/2024 13:47 11/13/2024 13:51 11/13/2024 13:55 11/13/2024 14:05 11/13/2024 14:06 11/13/2024 14:08 11/13/2024 14:08 11/13/2024 14:10 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Description of Image Exceedance K7 at well 470R Exposed waste and above ground GCCS piping Erosion Exceedance G7 at well 446 Exceedance K8 at well 489R Exceedance G8 at well 465 Open venting at well 485 with disconnected pipe Open venting at well 485 with disconnected pipe Open venting at well 485 with disconnected pipe Open venting at well 507 with disconnected pipe Open venting at well 507 with disconnected pipe Exceedance G9 at well 506 Exceedance K9 at well 527 Exceedance K9 at well 527 Exceedance E13 at well 525 GCCS piping and exposed trash Exceedance E14 Exceedance E15 Well 488 uphill of exceedances E14 and E15 (entire slope below this well over 500ppm, we stopped placing flags and recording exceedances because it was every few feet) Exceedance K10 by header seam Exceedance E16 by header Unconfirmed exceedance E18 Erosion and exposed waste downhill of well 432R3 Exceedance K11 at well 432R3 Erosion and exposed waste Deep erosion gullies Exceedance K12 at well 452 Exceedance K13 at well 455 by old wells or possibly clean outs Exceedance G10 at well 435 Exceedance E19 ( large area elevated over 500 ppm but we counted as one exceedance) Exceedance E20 at erosion gully by header Erosion gully with flagging waste Exposed waste Erosion gullies with flagging waste Exposed waste MAP ID (See App C) 25 26 27 28 29 30 30 31 32 33 34 35 37 38 39 41 40 42 43 Page 9 of 13 Image # 108 109 110 111 112 113 114 115 116 117 118 119 File Name IMG_1817.JPG IMG_1818.JPG IMG_1819.JPG IMG_1820.JPG IMG_1821.JPG IMG_1822.JPG IMG_1823.JPG IMG_1824.JPG IMG_1825.JPG IMG_1826.JPG IMG_1827.JPG IMG_1828.JPG Date and Time 11/13/2024 14:20 11/13/2024 14:25 11/13/2024 14:28 11/13/2024 14:30 11/13/2024 14:33 11/13/2024 14:38 11/13/2024 14:42 11/13/2024 14:45 11/13/2024 14:47 11/13/2024 14:49 11/13/2024 14:52 11/13/2024 14:52 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Description of Image Exceedance K14 at well 337 Exceedance K15 at well 316 Exceedance E21 Exposed waste Unconfirmed exceedance E22 at well 355R2 Exceedance G11 at well 314R Exceedance E23 Solidification Pit Exceedance E24 Solidification Pit Exposed waste Exposed waste and pooling water MAP ID (See App C) 44 45 46 47 48 49 50 Page 10 of 13 APPENDIX B: FIELD MEASUREMENT DATA Site Name: Clark Floyd 50 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 Measured Exceedances MAP ID Timestamp (see App C) 1 11/13/2024 10:12 2 11/13/2024 10:12 3 11/13/2024 10:20 4 11/13/2024 10:28 5 11/13/2024 10:34 6 11/13/2024 10:44 7 11/13/2024 10:51 8 11/13/2024 10:57 9 11/13/2024 10:59 10 11/13/2024 11:05 11 11/13/2024 11:07 12 11/13/2024 11:13 13 11/13/2024 11:16 14 11/13/2024 11:30 15 11/13/2024 11:37 16 11/13/2024 11:38 17 11/13/2024 11:40 18 11/13/2024 11:42 19 11/13/2024 11:50 20 11/13/2024 11:54 21 11/13/2024 11:57 22 11/13/2024 12:01 23 11/13/2024 12:06 24 11/13/2024 12:11 25 11/13/2024 12:15 26 11/13/2024 12:18 27 11/13/2024 12:29 28 11/13/2024 12:36 29 11/13/2024 12:42 30 11/13/2024 12:48 31 11/13/2024 12:52 32 11/13/2024 13:03 33 11/13/2024 13:08 34 11/13/2024 13:13 35 11/13/2024 13:16 Irwin Reading (ppm) 1881 613 653 529 3174 3426 952 761 2839 675 13419 643 644 846 1283 1195 1869 2383 2737 948 963 1071 14129 702 1145 1460 7530 1406 8382 8714 6118 4055 1217 684 1818 Confirm Reading (ppm) 600 667 700 1060 2231 1785 2498 1775 27892 605 755 555 4829 1026 656 944 2531 1307 5662 4550 592 1370 7010 2006 1009 14036 13924 2139 617 983 852 1129 Comments Erosion Erosion Erosion Erosion Well 308R Erosion Well 286 Erosion Well 326 Well 345 Well 346 Leachate Erosion Erosion Erosion Well 405 Erosion Well 387R Old Well 426 Well 447R Erosion Well 409 Well 429 Erosion Well 470R Well 446 Well 489R Well 465 Well 506 Well 527 Well 525 Erosion Erosion Header seam Header Latitude (WGS84) 38.457094 38.457248 38.457098 38.457039 38.456806 38.45678 38.456102 38.456218 38.456209 38.455836 38.456308 38.456357 38.456404 38.456199 38.456373 38.455922 38.456415 38.456467 38.456284 38.45653 38.456575 38.457045 38.456978 38.456707 38.457329 38.456351 38.456836 38.456028 38.456203 38.456566 38.455987 38.456732 38.456757 38.456973 38.456738 Longitude (WGS84) -85.836662 -85.836459 -85.836176 -85.836195 -85.836026 -85.836161 -85.836659 -85.835968 -85.835816 -85.835321 -85.834992 -85.834934 -85.834706 -85.833782 -85.833728 -85.832879 -85.833616 -85.83355 -85.832381 -85.831903 -85.831872 -85.83264 -85.832094 -85.831694 -85.831302 -85.831344 -85.830036 -85.830445 -85.829531 -85.829006 -85.829111 -85.830251 -85.830473 -85.831058 -85.830964 Irwin Instrument ID 92004350 92005482 92005482 92004352 92005482 92004352 92004350 92004352 92004350 92005482 92004352 92004352 92004352 92004350 92004352 92005482 92004352 92004352 92004350 92005482 92004350 92004352 92004352 92004352 92004350 92005482 92004350 92005482 92005482 92004350 92004352 92004352 92004352 92004350 92004352 Page 11 of 13 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 MAP ID (see App C) 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Timestamp 11/13/2024 13:20 11/13/2024 13:30 11/13/2024 13:34 11/13/2024 13:42 11/13/2024 13:46 11/13/2024 13:50 11/13/2024 13:56 11/13/2024 14:06 11/13/2024 14:21 11/13/2024 14:26 11/13/2024 14:30 11/13/2024 14:34 11/13/2024 14:40 11/13/2024 14:44 11/13/2024 14:49 Irwin Reading (ppm) 7006 744 2424 11031 741 7713 2757 796 1948 2177 728 597 12596 1203 1455 Confirm Reading (ppm) 2223 1106 19503 1937 792 3642 712 719 1863 901 1637 946 747 Comments Well 487R Erosion Well 432R3 Well 452 Well 435 Well 455 Erosion Erosion Well 337 Well 316 Erosion Well 355R2 Well 314R Erosion Erosion Latitude (WGS84) 38.456657 38.457067 38.457974 38.458244 38.459163 38.459081 38.459344 38.459568 38.459536 38.459278 38.459029 38.458805 38.458727 38.45819 38.457991 Longitude (WGS84) -85.831022 -85.831567 -85.83186 -85.831639 -85.832001 -85.83143 -85.831523 -85.831908 -85.835426 -85.835996 -85.835442 -85.835211 -85.836002 -85.835618 -85.836277 Irwin Instrument ID 92004352 92004352 92004350 92004350 92005482 92004350 92004352 92004352 92004350 92004350 92004352 92004352 92005482 92004352 92004352 Calibration and Instrument Information EPA used three Elkins Irwin devices. Irwin Calibration Data Irwin 50 (S/N 92004350) Measurement Cal (ppm) RT (sec) 1 491 1 2 491 3 3 491 0 *Cal = Calibration Gas Reading (ppm) *RT = Response Time (sec) Irwin 52 (S/N 92004352) Cal (ppm) RT (sec) 490 0 490 2 490 3 Irwin 82 (S/N 92005482) Cal (ppm) RT (sec) 497 0 496 0 497 0 Background Readings: Upwind: 0 ppm Downwind: 0 ppm EPA Calibration Gases Composition Zero Air Methane in air 500 ppm Lot # Atmospheric 304-402518883-1 Expiration N/A 8/2026 Page 12 of 13 Facility Name: Clark-Floyd Landfill Facility Location: 14304 SR 60, Borden, Indiana Date of Inspection: November 13, 2024 APPENDIX C: FIELD MEASUREMENT DATA MAPS Recorded highest SEM hit locations are mapped on top of satellite imagery with the approximate monitoring path. The numbers correspond to MAP IDs that are presented in Appendix B. Integrated GPS monitoring points collected every 10 seconds during SEM are mapped over satellite imagery of the landfill. Concentrations of methane (ppmv) are shown using a color scale. The 10 second readings stop when recording a max reading, leading to some variation relative to hits above. Page 13 of 13