Document jBxVdXJwrEvegmXDOBQwNLN3N

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT WM Earthmovers Landfill, Elkhart, IN FROM: Emma Leeds, Environmental Engineer AECAB (IL/IN) Jacob Herbers, Environmental Engineer AECAB (MI/WI) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Waste Management (WM) Earthmovers Landfill, Elkhart, IN Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 EPA Inspector(s): 1. Emma Leeds, Environmental Engineer 2. Jacob Herbers, Environmental Engineer Other Attendees: 1. Brian Wigent, Environmental Manager - IDEM 2. Randy Russell, Indiana Gas Operations Manager - WM 3. Neal Carswell, Renewable Energy Plant Manager - WM Contact Email Address: rrussell@wm.com; bcarswel@wm.com Purpose of Inspection: To determine compliance with the Clean Air Act (CAA) and conduct surface emissions monitoring (SEM). Facility Type: Municipal solid waste (MSW) landfill Facility Name: WM Earthmovers Landfill Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 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: 11:40 EST Departure Time: 2:40 EST Inspection Type: Unannounced 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 WM personnel unless otherwise noted. Process Description: Earthmovers Landfill ("the Landfill" or "the Facility") is an MSW landfill that began operating in 1976, stopped accepting waste in 2023, and finished installing final cover on the landfill in 2024. The landfill gas (LFG) collection system has approximately 100 interior gas extraction wells in total. Gas is primarily routed to the on-site gas-to-energy facility at the northwest corner of the property with six rotating internal combustion engines. The gas-to-energy facility is owned by Wabash Valley Power, and operated by WM. Excess gas is also sent to the open flare at the central northern edge of the property. Staff Interview: The entire landfill was under final cover at the time of the inspection. Within the previous year, several new remediation wells had been installed outside the waste boundary of the landfill to address gas migration detected at gas boundary probes, including RW-14 and RW-15 at the central northern edge of the landfill. These remediation wells are connected to the gas collection and control system (GCCS). TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: The EPA performed SEM at the landfill using two Inficon IRwin devices (IRwin). The IRwin 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. The EPA performed SEM at various locations along the Page 2 of 6 Facility Name: WM Earthmovers Landfill Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 eastern and northern slope of the landfill at areas with distressed vegetation and at wellhead penetrations and did not find any exceedances of 500 parts per million (ppm) methane. The EPA also performed SEM in areas near boundary gas probes that had indicated gas migration within the past year, and around exterior gas remediation wells, and also did not find exceedances of 500 ppm in these areas. The EPA inspected the landfill's flare and detected a 1,926 ppm methane leak from a bolt on a flange at the GCCS blower discharge outlet, which routes gas directly to the flare (Images 10-11). The EPA drove around all four slopes of the landfill to observe the cover integrity from the perimeter. No major cover integrity issues were observed. The EPA inspected the gas-to-energy facility and observed at least two of the engines running and visible emissions from an exhaust point outside the gas-to-energy facility. Inside the facility, methane gas was leaking from components on the pipes leading to the engines, including from the flexible metal mesh pipes immediately before the engines (Images 20-21). The EPA inspectors took IRwin measurements of these leaks, as noted in Appendix B. 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. The EPA inspectors performed surface emissions monitoring of methane emissions at the landfill, and leak monitoring at the gas control facilities using 2 IRwin devices. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Concerns: The EPA inspectors expressed concerns about landfill gas leaks from the gas-to-energy facility and the flare. DIGITAL SIGNATURES Leeds, Digitally signed by Leeds, Emma Date: 2025.01.03 Report Author: _E_m__m__a________14_:0_1:_28_-0_6'_00_' ____________ NATHAN Digitally signed by NATHAN FRANK Section Supervisor: _F__R_A_N__K_______15_:4_2_:33_-_06_'0_0' _____________ Date: 2025.01.03 Page 3 of 6 Facility Name: WM Earthmovers Landfill Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log 2. Appendix B: Field Measurement Data Page 4 of 6 Facility Name: WM Earthmovers Landfill Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 APPENDIX A: DIGITAL IMAGE LOG Inspector Names: Emma Leeds and Jacob Herbers | Archival Record Location: EPA Electronic Records # File Name 1 PB190001.JPG 2 WIN_20241119_11_31_51_Pro.jpg 3 PB190002.JPG 4 PB190003.JPG 5 WIN_20241119_12_10_30_Pro.jpg 6 WIN_20241119_12_10_44_Pro.jpg 7 WIN_20241119_12_12_54_Pro.jpg 8 PB190004.JPG 9 PB190005.JPG 10 WIN_20241119_13_42_27_Pro.jpg 11 WIN_20241119_13_42_39_Pro.jpg 12 PB190006.JPG 13 PB190007.JPG 14 PB190008.JPG 15 PB190009.JPG 16 PB190010.JPG 17 PB190011.JPG 18 PB190012.JPG 19 PB190013.JPG 20 WIN_20241119_14_35_52_Pro.jpg 21 WIN_20241119_14_35_56_Pro.jpg Date & Time (EST) 2024:11:19 12:24:41 2024:11:19 12:31:52 2024:11:19 12:36:05 2024:11:19 12:36:11 2024:11:19 13:10:32 2024:11:19 13:10:44 2024:11:19 13:12:54 2024:11:19 13:30:30 2024:11:19 13:35:31 2024:11:19 13:42:28 2024:11:19 13:42:39 2024:11:19 13:44:42 2024:11:19 13:49:11 2024:11:19 14:06:20 2024:11:19 14:07:16 2024:11:19 14:16:16 2024:11:19 14:16:19 2024:11:19 14:24:38 2024:11:19 14:34:57 2024:11:19 14:35:53 2024:11:19 14:35:57 Description Out-of-refuse remediation well RW-9 Accidental View of southern half of east slope of landfill View of eastern half of south slope of landfill View of east slope of landfill, looking north View of east slope of landfill, looking south View of east slope of the landfill New remediation wells installed within previous year: RW-14 (closest), RW-15, RW-13 (green), RW-12 (green), RW-11 (furthest back) View of north slope of the landfill Flare blower discharge outlet where leak was observed Rusted bolt on flange at flare blower discharge outlet where leak was observed Tall vegetation on north slope of landfill Dense vegetation on the north slope of the landfill View of southern portion of west slope of the landfill View of northern portion of west slope side of the landfill Engines (blurry/error) Engines (blurry/error) Engines (blurry/error) Engines (blurry/error) Engines Engines Page 5 of 6 APPENDIX B: FIELD MEASUREMENT DATA Facility Name: WM Earthmovers Landfill Facility Location: 26488 Co Rd 26, Elkhart, IN 46517 Date of Inspection: November 19, 2024 Irwin Monitoring Data ID IRwin reading (ppm CH4) Description 1 1,924 Flare blower outlet HS1 pipe fitting 2 261 Engine #4 right flexible pipe 3 315 Engine #6 left flexible pipe 4 90 Engine #6 right flexible pipe Date/Time (EST) 11/19/24, 1:39 PM 11/19/24, 2:27 PM 11/19/24, 2:32 PM 11/19/24, 2:33 PM IRwin 1 (S/N: 92005482) Calibration at 11:23 EST Measurement Verification reading Response for 500 ppm gas Time #1 496 1 #2 497 3 #3 494 3 IRwin 2 (S/N: 92005974) Calibration at 11:22 EST Measurement Verification reading Response for 500 ppm gas Time #1 494 2 #2 495 1 #3 495 0 EPA Calibration Gases Calibration gas Zero air Methane in air 523 ppm Lot no. 230383 304-4031015581 Expiration date May 2027 July 2028 Background Concentrations Upwind Downwind 0 ppm 0 ppm Page 6 of 6