Document emYyq3VXj2wK2V0JaEK9B14bm

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Republic Services Livingston Landfill, Pontiac, IL FROM: Giles Chickering, Physical Scientist AECAB (MI/WI) Jacob Herbers, Environmental Engineer AECAB (MI/WI) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: 05/22/2025 EPA Inspector(s): 1. Giles Chickering, Physical Scientist 2. Jacob Herbers, Environmental Engineer 3. Aileen Drum, Physical Scientist 4. DeMarkus Hodge, Environmental Engineer 5. Sasa Dunovic, Environmental Engineer 6. Ethan Chatfield, Environmental Engineer Other Attendees: 1. Julie Paramo, Operations Manager, Republic 2. Todd Cradduck, Operations Supervisor, Republic 3. Eric Dippon, Environmental Manager, Republic 4. Matt Nimbler, Environmental Systems Manager, Republic 5. Paxton Richards, Environmental Specialist, Republic Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 6. Caleb Painter, Gas Technician, Republic 7. Zach Woodburn, GM for landfill, Republic 8. Megan Crowley, Area Environmental Manager, Republic 9. Niki Westenberg, Sr Manager of Air Program, Republic 10. Sarah Brown, Air Consultant, Weaver Consultants 11. Rachelle Maxheimer, Air Consultant, Weaver Consultants Contact Email Addresses: edippon@republicservices.com; japarano@republicservices.com; tcradduck@republicservices.com. Purpose of Inspection: Clean Air Act Inspection Facility Type: Municipal solid waste (MSW) Landfill Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart XXX, 40 C.F.R. Part 63, Subpart AAAA, and Livingston's CAAPP permit (I.D. No.: 105821AAO, Permit No.: 97030075). Arrival Time: 9:50 CDT Departure Time: 15:20 CDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from Livingston Landfill staff, unless otherwise noted. Process Description: Livingston Landfill accepts MSW, as well as construction and demolition (C&D) debris, asbestos, and other Illinois classified special wastes that are comingled in the same points of disposal. The Landfill consists of two main hills; a southern hill that is fully under final cover, and a northern hill that actively accepts waste. The southern hill was permitted in 1978 and started accepting waste in the late 1970s or early 1980s. Older portions (eastern portion of the south hill) are unlined. The northern hill has Page 2 of 8 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 about 20 more years of capacity to accept waste. The Landfill receives about 4,000 tons per day. The landfill uses tarps in lieu of soil for of daily cover. Livingston Landfill has two enclosed flares (6,000 scfm each) and one candlestick flare (2,068 scfm) on site. A gas-to-energy plant with three turbines (approximately 2,000 scfm each) converts landfill gas to energy. The gas plant is owned by Hoosier Energy and operated by Ameresco under a contract with Republic Services. The goal is to operate the gas-to-energy plants at full capacity, but flares are also run to maintain the vacuum set point of the well field. The gas-to-energy plant has been operating for approximately 10 years. It was previously shut off for 10 years prior to reopening (approximately 2005-2015), but was operational before that 10-year period of dormancy (before 2005) for an unspecified amount of time. Staff Interview: Livingston Landfill accepts waste 5:30 AM to 3:00 PM Monday through Friday and 5:30 AM to 10:00 AM on Saturdays. The Landfill has approximately 26 employees, plus consultants and contractors on site. Republic Services employs two gas technicians that are on site and tuning/maintaining the well field most days of the week. Civil and Environmental Consultants perform surface emission monitoring (SEM) at the landfill quarterly. SEM is conducted by doing simultaneous serpentine path and penetration monitoring events. Monthly cover integrity checks are performed and recorded electronically. No significant issues were reported for cover integrity during the opening conference. Cover integrity repairs were described to be repaired within one to two days. Livingston Landfill works to maintain the vacuum set point of 41 inches of water column in the well field consistently. The site used to have some HOV wells and they may still be in place. Alternative operating conditions may include seven or eight leachate clean out risers. Livingston landfill has boundary probes for monitoring with no known issues. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: The EPA inspectors conducted SEM on the north hill, and parts of the south hill of the Landfill. The EPA discovered 20 SEM hits above 500 ppm, listed in Appendix B. Photos corresponding to most of the EPA SEM hits are listed in the table in Appendix A. Additional photos document examples of surface integrity issues, including erosion and leachate seeps on the surface of the Landfill. 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. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 8 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 Requested documents: A copy of the most recent Design Plan for Livingston. If the SEM pathway is separate from the design plan, please send that as well Semi-annual reports since January 1, 2022 to present Manufacturer's specifications for all controls and initial performance test report(s), including supplemental information required in 40 CFR 63.1981(i). Continuous flow records to control devices (15-min intervals) (40 CFR 63.1983(c)(2)). if there's multiple control devices, provide both the individual flows to each control, and the total flow. Please provide this information from January 1, 2022 to present. Up-to-date plot map showing which areas are under final, intermediate, and daily cover, and showing each existing and planned gas collection device and gas probe with a unique identification label and the installation date for each. A table with gas collection device (well, probe) numbers and dates of installation can be substituted for labeling these items on the map Monthly wellhead monitoring records for parameters measured per 40 CFR 63.1961(a)(1) through (6), including records of all collection and control system exceedances of the operational standards (40 CFR 63.1983(e)(1)), along with any related root cause analyses and corrective action analyses. (40 CFR 63.1983(e)(1)(3) - (5)). Please provide this information from January 1, 2022 to present in Excel/spreadsheet format. Quarterly records of liquid levels in wells from January 1, 2022 to present. Monthly cover integrity reports January 1, 2022 to present. A list/table of any HOVs or other alternative operating conditions currently in place at the Landfill. Concerns: SEM exceedances listed in the table in Appendix B, especially the exposed flexible pipe venting gas (Hit #15). DIGITAL SIGNATURES JACOB Digitally signed by JACOB HERBERS HERBERS Date: 2025.07.09 16:59:21 -05'00' Report Author: _________________________________ NATHAN Digitally signed by NATHAN FRANK FRANK Date: 2025.07.14 10:52:03 -05'00' Section Supervisor: __________________________________ Page 4 of 8 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 APPENDIX A: DIGITAL IMAGE AND VIDEO LOG Inspector Name: Giles Chickering and Jacob Herbers Archival Record Location: EPA Electronic Records 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 File Name G-P5220073.JPG G-P5220074.JPG G-P5220075.JPG G-P5220076.JPG G-P5220077.JPG G-P5220078.JPG G-P5220079.JPG G-P5220080.JPG G-P5220081.JPG P5220069.JPG P5220070.JPG P5220071.JPG P5220072.JPG P5220073.JPG P5220074.JPG P5220075.JPG P5220076.JPG P5220077.JPG P5220078.JPG P5220079.JPG P5220080.JPG P5220081.JPG P5220082.JPG P5220083.JPG P5220084.JPG P5220085.JPG P5220086.JPG P5220087.JPG P5220088.JPG P5220089.JPG P5220090.JPG P5220091.JPG P5220092.JPG Date & Time 5/22/2025 12:43 5/22/2025 12:43 5/22/2025 12:51 5/22/2025 12:51 5/22/2025 13:08 5/22/2025 13:34 5/22/2025 13:41 5/22/2025 13:47 5/22/2025 13:50 5/22/2025 10:22 5/22/2025 11:09 5/22/2025 11:09 5/22/2025 11:20 5/22/2025 11:23 5/22/2025 11:24 5/22/2025 11:30 5/22/2025 11:34 5/22/2025 11:35 5/22/2025 11:40 5/22/2025 11:53 5/22/2025 11:59 5/22/2025 12:06 5/22/2025 12:17 5/22/2025 12:24 5/22/2025 12:31 5/22/2025 12:35 5/22/2025 12:52 5/22/2025 12:56 5/22/2025 12:59 5/22/2025 13:03 5/22/2025 13:18 5/22/2025 13:36 5/22/2025 13:44 Image Description Hit near well 181A, exposed fabric Hit near well 181A, exposed fabric Hit near well 173A Hit near well 173A Hit near well 175A Hit on cover integrity near well 2B Leachate coming through surface Hit near well 234B, below leachate puddle Hit at well 234B IRwin probe distance check West slope North slope Well 241, surrounding distressed vegetation Erosion by well 250 Erosion by well 250 Well 251 Well 252 Gully on NW slope Exposed trash on NW slope North slope, tracks in soil Well 256 Well 6 A North slope erosion near well 204 Well 200 Exposed flexipipe North slope erosion Well 3C Well 5B Well 246, standing water Well 245A, standing water Erosion rills and cracks on West slope Excavator and road near hit Excavator and road near hit Page 5 of 8 Video # 1 2 3 4 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 File Name FLIR0461.mp4 FLIR0462.mp4 FLIR0463.mp4 FLIR0464.mp4 Date and Time 5/22/2025 15:11 5/22/2025 15:40 5/22/2025 15:45 5/22/2025 15:50 Video Description Gas-to-energy turbine exhausts from the North Turbine exhausts and flare from the south Turbine exhausts and flare from the south Gas-to-energy turbine exhausts from the North Page 6 of 8 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 APPENDIX B: FIELD MEASUREMENT DATA Instrument Information Instrument Inficon IRwin #1 (S/N: 92004352) Inficon IRwin #2 (S/N: 92004350) Inficon IRwin #3 (S/N: 92005974) Inficon IRwin #4 (S/N: 92005482) EPA Inspector Aileen Drum DeMarkus Hodge Ethan Chatfield Sasa Dunovic Calibration Gas Information Cal Gas Composition Air, zero grade Methane, 523 ppm Lot/Serial Number 3-116-85 304-403101558-1 Expiration Date 5/20/2027 7/24/2028 IRwin #1 Calibration Check @ 10:39 CDT Cal Gas Level IRwin Reading (ppm) Run 1 Run 2 Run 3 0 0 0 0 523 515 516 514 IRwin #2 Calibration Check @ 10:38 CDT Cal Gas Level IRwin Reading (ppm) Run 1 Run 2 Run 3 0 0 0 0 523 514 515 514 IRwin #3 Calibration Check @ 10:39 CDT Cal Gas Level IRwin Reading (ppm) Run 1 Run 2 Run 3 0 0 0 0 523 515 516 516 IRwin #4 Calibration Check @ 10:37 CDT Cal Gas Level IRwin Reading (ppm) Run 1 Run 2 Run 3 0 0 0 0 523 523 521 520 Upwind and Downwind Readings Upwind reading (ppm methane) 0 Downwind reading (ppm methane) 0 Page 7 of 8 Facility Name: Livingston Landfill Facility Location: 14206 East 2100 North Road Pontiac, Illinois 61764 Date of Inspection: May 22, 2025 EPA Reading Confirmation SEM (ppm Reading (ppm Hit # CH4) CH4) 1 855 758 2 827 885 3 1628 1094 4 752 1066 5 738 934 6 559 590 7 1422 985 8 8194 2218 9 1120 1057 10 2473 1594 11 880 734 12 822 1513 13 627 542 14 643 912 15 67880 18723 16 825 1000 17 1164 897 18 587 514 19 506 596 20 1302 1224 Latitude Longitude Description 40.9345 40.93449 40.93415 40.93403 40.93423 40.93425 40.93491 40.93547 40.93601 40.93614 40.93615 40.93592 40.9361 40.9355 40.93555 40.93454 40.93541 40.9349 40.9354 40.93292 -88.6524 -88.6534 -88.6548 -88.6563 -88.6578 -88.6582 -88.6606 -88.6613 -88.6613 -88.6588 -88.6581 -88.6567 -88.6548 -88.6543 -88.6524 -88.6565 -88.6565 -88.6573 -88.66 -88.6617 Hit near well 181A, exposed fabric Hit near well 173A Hit near well 175A Hit on cover integrity near well 2B Hit near well 234B, below leachate puddle Hit at well 234B Hit near well 241 Hit near well 251 Hit near well 252 Hit near well 255 Hit near well 256 Hit near well 6A Hit near well 204 Hit near well 200 Exposed flexipipe Hit near well 3C Hit near well 5B Hit near well 245A Hit on erosion rills Hit on road near excavator Page 8 of 8