Document evzw3vQBgJk0jQkoe1egajVE

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 Below CLEAN AIR ACT INSPECTION REPORT Waste Management - Prairie Hill Landfill, Morrison, Illinois Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, Illinois 61270 Date of Inspection: June 2, 2021 and June 17, 2021 EPA Inspector(s): 1. Vicky Mei, Environmental Engineer 2. Daniel Heins, Environmental Scientist Other Attendees on June 2, 2021: 1. Pat Brahmer, Surface Emission Monitoring (SEM) Technician, Environmental Monitoring Technologies Other Attendees on June 17, 2021: 1. Michael Melan, Environmental Manager, Waste Management 2. Steven Niehoff, Director of Air Programs, Waste Management Contact Email Address: Mike Melan, Mmelan1@wm.com Purpose of Inspection: Comparative surface emission monitoring (SEM) and Clean Air Act (CAA) inspection Facility Type: Municipal Solid Waste Landfill Regulations Central to Inspection: NSPS Subpart WWW; NESHAP Subpart AAAA June 2, 2021: Arrival Time: 10:05 A.M. Departure Time: 3:48 P.M. June 17, 2021: Arrival Time: 1:00 P.M. Departure Time: 3:45 P.M. 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 Mr. Brahmer, Mr. Melan, and Mr. Niehoff unless otherwise noted. Process Description and Staff Interview: Prairie Hill Landfill (the Landfill or Facility) has been subject to the NSPS since 2006. Staff that work with the gas collection and control system (GCCS) includes 4 gas operators, an operations manager, and a well technician. There are no expansion plans at the time of the inspection. The accepted waste stream includes 60% municipal solid waste (MSW), 30 to 40% inerts and construction and demolition (C&D) waste. The Facility considers inerts and "nondegradable waste" to include contaminated soils, concrete, auto fluff, and simple organics like plastics. In 2020, the facility accepted 18 tons of C&D. The inerts are removed from the LandGEM calculations if scale house data is available. The inerts are intermingled with the MSW and the location is not documented, except for the locations of asbestos, which is separated and covered. The facility's internal definition of "special waste" includes C&D and wood chips. No significant amount of leachate was recirculated since 2018-2019. The Facility recirculated 3,000 gallons of leachate in 2020 and none in 2021 thus far. The leachate is being hauled out now. 40,000 gallons of leachate per day is hauled off-site by tanker trucks, drawing directly from the riser or the 20,000-gallon underground tank. The Facility has trouble finding enough publicly owned treatment works (POTW) to accept leachate. The Facility is permitted in the past 6 Page 2 of 7 months to install and operate a leachate evaporation unit, and started the construction process, which is projected to be done by mid-2022. 45,000 gallons of leachate per day will be processed once the unit is up and running. Heat from the landfill gas would be used to heat the evaporator. The Facility is working with Landfill Gas Specialties on considering factors such as the cost of hauling leachate (5 to10 per gallon) and other options. There has not been any groundwater exceedances nor quarterly gas probes hits. The most recent well water level measurements were taken in May 2020 and September 2020, as part of the hazardous air pollutant (HAP) program. Generally, the Facility measures the water levels in wells every couple of years. Moving forward, the Facility will monitor two times per year so to have historical tracking data to see trends in the overall GCCS management. The well water pumps are checked when measuring gas well parameters. The Facility has 1 blower and 1 flare, both of 4,000 cubic feet per minute (cfm) capacity. There is no back-up blower. The system vacuum is at 50% to 55% capacity. The Facility aims to maintain 30 inches of water column ("w.c.), even on the far side of the site. If there is a blockage, such as due to a sag in a pipe or a surge in the system, segments in the system are segregated. Differential pressure is monitored downstream to determine system pressure in a particular section of the GCCS and available vacuum. The Facility uses the KYGas calculator to determine friction loss. The flare is non-assisted, monitored for gas flow rate and temperature, and has a system shutdown setpoint. The maximum heat input is 506 British thermal unit (BTU)/feet or 2 million BTU/min. Performance test conducted at the flare includes testing for velocity, BTU content, and visible emissions. The bag sample test at the utility flare is conducted annually and tests for methane, sulfur, and non-methane organic compounds (NMOC). The current gas flow rate is 2,300 to 2,400 cfm. According to LandGEM, methane generation is about 1,150 cfm, which matches with the assumption that 50% of the current gas flow rate is methane. Actual methane generation may be lower than shown on LandGEM because a portion of the gas stream comprises of inerts. The gas consists of 35 to 60% methane. The k value used in LandGEM is 0.2 and is adjusted based on factors, such as whether leachate is recirculated or not. Capping is anticipated to occur in the next 4 to 5 years as such, there will not be any areas at final grade soon. The last cell, Cell 6, was constructed 4 years ago. Well construction events occur annually and may last 3 to 6 months long. The most recent well installed was on the east side on the Landfill, west of the northeast corner of Cell 6. No new wells were drilled recently. Wells in the SEM areas by the flare are being raised. There has not been any fires nor subsurface oxidation events since 2010 at the Prairie Hill Landfill site. There was a fire at the Whiteside Landfill, which is a closed landfill acquired by Prairie Hill Landfill which may have been due to a broken pipe or airline. The area surrounding around the fire continues to be monitored monthly. Page 3 of 7 The size of the active fill area is about 2 acres or less. The active area at the time of the on-site inspection on June 2, 2021 is at Phase 5, Cell 1 and 2. The Facility defines dangerous areas excluded from surface emission monitoring (SEM) to include 4:1 slopes if the weather does not permit, such as during rainfall. At the time of the inspection, there is no area greater than 4:1, except a few small areas in the active area with 3:1 slope. Currently, the external slopes are at grade. The internal slopes are still operational and part of the working face. 25% of the exterior slopes are at 4:1 now. After the Landfill reaches grade and is capped, 70 to 80% of the Landfill will be 4:1 slopes. The well technician has conducted SEM for the past 5 years. The well technician present during the inspection relayed that the Facility's quarterly SEM has found few to no exceedances. The SEM path traversed includes only the portions of the Landfill that are in an "L" shape by the flare and the closed "football-field" shaped area of the Landfill. The SEM procedure includes monitoring at only specific points along the SEM path, as instructed and documented in a predrawn map provided to the well technician and does not consist of off-path monitoring nor penetration monitoring. The well technician monitors leachate in leachate points in the closed areas. Leachate protrusions are at the base of the Landfill, in the closed area, and include L308 and L309 on the north side of the Landfill. Horizontal collectors are installed throughout the Landfill. Only Phase 6 East does not have horizontal collectors because the waste is under 5 years old. Some of the early collection wells in areas of waste that is less than 5 years old are not up to standards because of the shallow depth of the waste. Horizontal collectors are installed on an as-needed basis, such as to control odors or to replace decommissioned wells. Wells are installed depending on filling sequence so that dozers or trucks do not run into the wells. The Facility does not conduct radius of influence (ROI) calculations beyond the final design of the GCCS. The effectiveness of the wells is compared to LandGEM calculations, SEM hits, and whether vacuum from neighboring wells are affecting nearby wells. The industry standard for ROI is 1 well/acre, although usually more wells are installed. As of the date of the inspection, the most recent permit is from 2019, and the most recent GCCS design plan and LandGEM calculations are dated 2014. The Facility does not have documentation on the cover integrity standard operating procedure. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: During Comparative SEM conducted by EPA, 51 SEM exceedances above 500 ppm were found. All of the hits, minus one, were confirmed by the Facility's well technician. Large areas of concern and with exceedances include the whole toe of the Landfill by GW-23. The entire side of the slope south of the active area by GW-406 had elevated SEM measurements, exceedance hits, leachate seeps, and exposed waste. The area within a 40 feet radius around GW-33 was elevated. Exposed waste was seen throughout the Landfill in areas that have not been filled for Page 4 of 7 an extended period of time. Healthy vegetation was minimal throughout the Landfill. Areas with vegetation have not been mowed. Audible bubbling liquid was heard and seen in liquid-filled holes. Strong gas odors were detected in areas with SEM exceedances, especially in areas where excessively high levels of methane were detected. A pool of liquid was on the top of the Landfill with exposed waste at EPA GPS Waypoint #134 (See Appendix B, Table 4). Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. Field measurements include monitoring methane levels at the surface of the Landfill. See Appendix B for exceedances found. RECORDS REVIEW 1. EMT SEM technician's SEM path map CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: SEM path map and confirmation of the most recent version of the permit. SEM path map taken for the past 5 years (Q2-2016 to Q1-2021). Results of both the 10-day rescans and the 30-day re-scans of the SEM hit locations found during EPA's inspection. Latest LandGEM model calculations with supporting back-up information used to determine Lo and k values. Drawing showing final, intermediate, and daily cover acres. Provide the number of acres under each type of cover and the size of the current fill area. Provide goals for vacuum across the site. Provide explanation for collectors not found by EPA during inspection - GW-405, GW403, HC-19 and GW-14. Verify if GW-48 was labeled at the time of EPA's SEM inspection. GPS coordinates of all the wells. 5 years of monthly cover integrity reports from 6/2016 to 5/2021. Gas probe readings from 5/2019 to Q1-2021. Construction permit submittal for the 4000-cfm flare. Device specifications for the existing 4000-scfm candlestick flare. 5 years of leachate extraction history (6/2016 to 5/2021). Provide waste stream acceptance by category from 6/2019 to 5/2021. Liquid levels obtained in wells from 5/2016 to date. Please make sure the documents have dates clearly written on them. Please include available perforation. SEM history from Q3-2019 to Q1-2021. Wellhead reads from 6/2019 to 5/2021, as well as the summary of wells that deviated from one of the monitored parameters. Page 5 of 7  History of HOV's submitted if any. Semi-annual compliance reports submitted to IEPA from 12/2019 to 12/2020. Flare start-up, shutdown, and malfunction (SSM) records and flow tracking from 2/2019 to 5/2021, including flare maintenance logs and monitored parameters. Results of annual landfill gas (LFG) sulfur tests performed in 2020 and 2021. "Annual open flare gas sampling" from 2020 and 2021. Current GCCS drawing. Running total reduced sulfur (TRS) emission data and accompanying calculations (hourly, monthly, annually) (6/2016-5/2021). Updated list of currently active wells and decommissioned wells since the information response submitted to EPA's June 24, 2019 114 information request. Quarter groundwater test reports, from Q2/2016-Q1/2021. Concerns: The SEM path that the EMT SEM technician traverses only covers the closed areas of the Landfill and at specific points in those areas. The technician relayed to EPA that this path and the points monitored are under the instruction of the previous Environmental Manager. The 51 exceedances that EPA detected and the observations listed in the above section, "Data Collected and Observations", are concerns. DIGITAL SIGNATURES Digitally signed by Mei, Mei, Vicky Vicky Date: 2021.08.16 Report Author: _____________1_0:2_7_:34_-_05_'0_0' __________________ Digitally signed by ETHAN CHATFIELD EDTaHteA: N20C21H.A08T.F1I6ELD Acting Section Chief: _____________1_0:_48_:5_2 -_05_'0_0'_____________ Page 6 of 7 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log 2. Appendix B: Field Measurement Data Page 7 of 7 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Vicky Mei and Daniel Heins 2. Archival Record Location: Electronic Record System Image Number 1 2 File Name 20210602_130826.jpg 20210602_130938.mp4 Date and Time (incl. Time zone and DST) August 2, 2021, 4:20 PM CST August 2, 2021, 4:20 PM CST Description of Image Photo of an SEM exceedance location above a hole with audible bubbling liquid Video of audible bubbling liquid in a hole with methane measurements over 2%. Appendices Page 1 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 APPENDIX B: FIELD MEASUREMENT DATA Calibration at 9:25 AM Table 1: Calibration Precision and Response Time TVA #1: A56575 Meter Readings of 500 ppm Calibration Gas Response Time 492 3.75 499 5.98 499 4.38 Average: 497 Average: 4.70 TVA #2: SL1555 Meter Readings of 500 ppm Calibration Gas Response Time 496 4.43 496 3.97 495 4.00 Average: 496 Average: 4.13 Upwind: -1.4 ppm at -89.879, 41.8044 (GPS Waypoint #116) Downwind: -0.8 ppm Table 2: Exceedance Values Exceedance # 1 EPA GPS Waypoint # 114 (TVA #1) Latitude -89.8818 Exceedance Values EMT GPS Waypoint Longitude # 41.80189 436 EPA Exceedance Reading (ppm) 1800 EMT Exceedance Reading (ppm) 700 2 115 -89.8817 41.801918 437 8500 4370 - 3 87 41.8042 89.880774 443 670 7187 1300 - (and 1300 with EPA 4 89 41.80506 89.879958 445 TVA #2) 763 2100 117 (and 2500 with EPA 5 (TVA #1) -89.8796 41.805322 448 TVA #2) 1106 - 6 90 41.80514 89.880042 446 1700 919 - 1600 (and 1000 with 7 105 41.80457 89.880707 444 EPA TVA #2) 1431 8 Location of GW-408. 441 3300 983 Appendices Page 2 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 118 9 (TVA #1) -89.881 41.803023 119 10 (TVA #1) -89.8811 41.802821 11 106 41.80271 -89.88106 120 12 (TVA #1) -89.8809 41.803394 1000 (and 2000 with 440 EPA TVA #2) 439 1000 438 6000 442 600 1150 1.24% 5092 1312 - 13 108 41.80541 89.880171 447 121 14 (TVA #1) -89.8817 41.804404 449 122 15 (TVA #1) -89.8818 41.804242 451 123 16 (TVA #1) -89.8818 41.804251 450 540 700 5% 2800 771 1047 9.99% (flamed out) 2.84% 17 124 -89.8818 41.804239 452 18 41.80392 89.88187 453 19 125 -89.8824 41.804111 454 20 126 -89.8825 41.804091 455 - 21 109 41.80391 89.882799 457 127 22 (TVA #1) -89.8827 41.804084 456 128 23 (TVA #1) -89.8828 41.804066 458 129 24 (TVA #1) -89.8835 41.804156 459 - 25 110 41.80395 89.883529 460 - 26 111 41.80395 89.883531 461 27 130 -89.8841 41.804165 28 131 -89.8843 41.803953 462 - 29 112 41.80359 89.883941 463 1% 3600 1300 644 1.30% 9800 1400 1200 3000 1300 790 1200 1400 2.57% 1.94% 1451 722 8.74% 0.83% 2250.00% 1.13% 5430 674 Not confirmed. 1389 1026 Appendices Page 3 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 - 30 113 41.80376 89.884457 464 31 132 -89.8832 41.806275 465 32 133 -89.8832 41.80629 466 33 41.8068 89.88263 467 114 - 34 (TVA #2) 41.80716 89.882106 468 117 - 35 (TVA #2) 41.80645 89.880056 469 118 - 36 (TVA #2) 41.80747 89.880212 470 37 135 -89.8809 41.80772 471 119 - 38 (TVA #2) 41.8074 89.881703 473 39 137 -89.8814 41.807771 472 40 138 -89.8814 41.807774 475 120 - 41 (TVA #2) 41.80744 89.882205 476 121 - 42 (TVA #2) 41.80737 89.881933 474 43 139 -89.8817 41.807776 477 122 44 (TVA #2) 41.8074 -89.88254 478 45 Location of GW-53. 479 123 - 46 (TVA #2) 41.80617 89.885306 480 127 - 47 (TVA #2) 41.8059 89.885236 481 48 140 -89.8854 41.805614 482 49 141 -89.8854 41.80515 484 128 - 50 (TVA #2) 41.80539 89.885302 483 129 - 51 (TVA #2) 41.80465 89.885557 485 2000 670 1500 2300 1400 1054 5% 5000 1600 2400 4139 812 2537 1704 1486 1798 9.90% 3441 992 2276 1500 3200 2000 513 820 1900 2% 1501 700 2200 2.50% 2.20% 3781 2931 1870 894 1112 3938 1.26% 1543 721 9.99% (flamed out) 3.75% 1.43% Appendices Page 4 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 Table 3: Exceedance Descriptions Exceedance # Location Description Exceedance Descriptions 75 ft West of flare; 50 ft North from road; 90 ft 1 downslope South of GW-23. 2 20 ft East of Waypoint #114. 3 4 50 ft downslope Southeast of GW-70. 5 30 ft North of BC5. 6 GW-70. Observations Dead vegetation at toe of landfill. Elevated measurements and exceedances found within 20 ft radius. Dead vegetation. Erosion. Dead vegetation. Erosion. 7 85 ft North of GW-22R. 8 GW-408. Erosion. 9 30 ft West of GW-408. 10 40 ft upslope of GW-407. 11 GW-407. 12 Between GW-407 and GW-406. 110 ft North of GW-70; 100 ft upslope of BC5; in 13 between GW-70 and GW-69. 14 GW-406. 15 50 ft South of GW-406; South of fill area. 16 50' S. of GW-406; South of fill area. 17 50' S. of GW-406; South of fill area. 18 Distressed veg + leachate stain/washout 19 Between GW-406 and GW-33. 20 10' from EPA Waypoint #125. 21 22 GW-33. Appendices Page 5 of 11 No vegetation. Erosion trench. Bubbling leachate with audible gas escaping from huge hole. Huge area of side slope with exposed waste and leachate seeps. Leachate seep with audible bubbling in another huge hole. Audible bubbling in another nearby hole. Whole side of slope with leachate filled holes and elevated methane readings and exceedances within 20 ft radius. Leachate and distressed vegetation. Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 23 20' W. of GW-33. 24 Between GW-33 and GW-41. 25 20' W. of GW-34. 26 40' uphill of GW-40. 27 GW-41. 28 100' W. of GW-41. 29 GW-39. 30 By the road. 31 32 In what appeared to be auto fluff (central area of 33 top) 34 HC19. 35 East slope; 60' W. of GW-68. 100' uphill of Southeast Leachate Riser, hole in 36 rivulet 37 38 30' E of W59 / north slope rivulet Many exceedances detected within 40 ft radius of GW-33. Exceedance in hole. Cracks in washout. Erosion. Erosion trench. Inactive area with uncovered waste. Erosion. Erosion; elevated measurements within 10 ft radius. 39 50' S. of road; 100' W. of Leachate-308. 150 ft West of Leachate-308; 50 ft upslope from 40 road on North slope. 41 Rivulet 40' W of W59 42 Well 59 (in rivulet) 43 30' upslope from road and GV-17. Dried discolored leachate seep. 44 By the exposed mattress immediately beside W58 45 GW-53. Strong gas odor. 46 Well 49 47 Well 52 Unmarked gas well; 100 ft South of GW-52 on West 48 slope. 49 GW-47. 50 Well 51 51 Well 50 Appendices Page 6 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 Table 4: Observations EPA Waypoint # Latitude 134 136 -89.881 -89.881 Longitude 41.8061 41.8077 Description Pooling at top of Landfill with exposed waste Leachate seep Bump Check with 500 ppm Calibration Gas at 3:35 PM TVA #1: 460 ppm TVA #2: 459 ppm Appendices Page 7 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 TVA #1 Comparative SEM Path Taken: (Map data from Google Maps 2021) Appendices Page 8 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 TVA #2 Comparative SEM Path Taken: (Map data from Google Maps 2021) Appendices Page 9 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 TVA #1 Exceedances Found: (Map data from Google Maps 2021) Appendices Page 10 of 11 Facility Name: Prairie Hill Landfill Facility Location: 18762 Lincoln Road, Morrison, IL 61270 Date of Inspection: June 2, 2021 TVA #2 Exceedances Found: (Map data from Google Maps 2021) Appendices Page 11 of 11