Document jg6mKgZw9eV18gyM9MODDREr9

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Newton County Landfill, Brook, IN FROM: Aileen Drum, Physical Scientist AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Republic Services Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 EPA Inspector(s): 1. Aileen Drum, Physical Scientist 2. Emma Leeds, Environmental Engineer 3. Linda Rosen, Environmental Engineer 4. Sasa Dunovic, Environmental Engineer 5. DeMarkus Hodge, Environmental Engineer 6. Giles Chickering, Physical Scientist Other Attendees: 1. Natalie Murray, Environmental Manager, Republic Services 2. Dave Stefl, Environmental Manager, Republic Services 3. Craig Drinski, Operations Manager, Republic Services 4. Jessica Linscott, Air Compliance Inspector, Indiana Department of Environmental Management (IDEM) 5. Matthew Doffin, Field Technician, SCS Engineers 6. Jake Nelson, Field Technician, SCS Engineers Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 Contact Email Address: nmurray@republicservices.com , dstefl@republicservices.com Purpose of Inspection: To determine compliance with the Clean Air Act (CAA) and to perform a comparative Surface Emissions Monitoring (SEM) survey Facility Type: Municipal Solid Waste Landfill Regulations Central to Inspection: 40 C.F.R Part 63 Subpart AAAA--National Emissions Standards for Hazardous Air Pollutants for Municipal Solid Waste Landfills Requirements and 40 C.F.R Part 60 Subpart XXX--Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification After July 17, 2014 Arrival Time: 9:44 AM Departure Time: 5:18 PM 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 Natalie Murray, Dave Stefl, and Craig Drinski of Republic Services unless otherwise noted. Process Description: Newton County Landfill ("Newton County" or "the landfill") is a municipal solid waste landfill owned and operated by Republic Services located in Brook, IN. The landfill occupies 317 acres and expects to accept waste for 30-40 more years. The landfill accepts approximately 7-8 tons of municipal solid waste per day, which is about 75% of the total waste accepted. In addition to municipal solid waste, Newton County accepts construction and demolition (C&D) waste, contaminated soils, fly ash, asbestos, autoclaved medical waste, and other special wastes. Final cover comprises 70.9 acres, the active face encompasses 10 acres in cell 6, and everything else is under intermediate cover. Approximately 50% of the landfill gas (LFG) generated is sent to Cascades, a nearby pulp packaging factory that is powered by gas from Newton County. Gas directed to Cascades is treated by removing moisture from the gas and compressing it. A maximum flow rate of 2,000 scfm of LFG is accepted, and the energy generated is used to power boilers and make cartons for beverage packaging. The Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 remainder of the landfill gas generated by Newton County is routed to three flares on site. Enclosed flare #4 (FL100) and enclosed flare #3 (FL120) are located on the south side, enclosed flare #3 serves primarily as a backup. Enclosed flare #6 (Unit 6) is located on the north side. Approximately 84 million gallons of leachate are generated per year. Most leachate is partially treated on-site and then trucked offsite. Headspace air from the leachate treatment building and tanks is pulled by a blower system and routed to the north flare to aid in combustion. About 5 million gallons of leachate per year are directed to the pug mill, which receives fly ash from steel mills and mixes it with untreated leachate to weigh it down. The leachate/fly-ash mixture is then introduced directly into the waste stream. The facility is permitted to operate two leachate injection wells, which Newton County plans to have up and running in the next several weeks. Staff Interview: The facility operates with approximately 55 employees. Newton County was publicly owned by the county before it was purchased by Republic Services in 2008 or 2009. In 1995, while still publicly owned, all waste on the south hill was relocated and placed into a liner. Most of the waste on the north hill has been in place for less than five years. SEM is done by SCS Engineers (SCS) and typically takes two technicians one week to complete. First, they walk a serpentine path and then they come back around to monitor the wells. Natalie Murray stated SCS does not deviate from the serpentine path. Facility personnel were not sure of the exact number of gas extraction wells at the facility, but stated there are 438 "compliance points", which include vertical wells, horizontal wells, sumps, and cleanouts. Approximately 95% of all well are vertical wells. The last SEM survey was at the end of May and staff were unsure how many exceedances were found, but believed there were not many. Newton County has over 200 wells with higher operating values (HOVs) approved by IDEM. Staff stated they used to take waste from Cleveland Cliffs, including aluminum dross sludge that generated a lot of heat, and as a result many of the wells on the south side have HOVs. Natalie Murray stated that there are no known issues associated with the wells operating at higher temperatures and that there are no known issues with the liner. Newton County has experienced issues with watered in wells. They have made efforts to dewater the wells and have conducted many redrills. Approximately 208 wells have dewatering pumps, and this is an everchanging target. Decisions regarding when a dewatering pump is installed have to do with gas quality and flow. There has been no leachate recirculation since 2015. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Six EPA inspectors conducted SEM at Newton County for approximately four and a half total hours. Measurements were taken with two Inficon IRwins (IRwin) and two Thermo Fischer Toxic Vapor Analyzer 2020 devices (TVA). Inspectors split into two groups, each equipped with one IRwin to record exceedances of methane above 500 ppm and one TVA to provide confirmation readings. The SEM Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 IRwin and TVA probe inlets were held 10 centimeters from the ground during SEM, with the probe inlet taped 10 cm from the bottom of the walking sticks on the IRwins, as shown in photos 1 and 2. Measurements were taken at the surface of the landfill, including areas of distressed vegetation and cracks in the cover, and at penetrations. In the morning, Inspectors Leeds, Hodge, and Chickering (Team 1) traversed the southeastern portion of the landfill accompanied by Natalie Murray and Jake Nelson. Inspectors Drum, Dunovic, Rosen, and Linscott (Team 2) traversed the south-central portion of the landfill accompanied by Dave Stefl and Matthew Doffin. Matthew Doffin reiterated that a SEM survey is conducted in two steps; in one step they monitor the penetrations, or "compliance points," and in the other they walk a serpentine path. SCS staff stated they do not deviate from the serpentine path and their probe is held 6 inches from the ground. They later said the probe is held 4 inches from the ground. The SCS technicians brought their own IRwins to independently confirm exceedances of 500 ppm. Most of the exceedances detected by Team 2 were confirmed verbally by Matthew Doffin. Exceedances detected by Team 1 were confirmed verbally and through the alarm initiated by Jake Nelson's IRwin. Both teams observed areas with cracks, erosion, distressed vegetation, and exposed waste, documented in photos 4, 5, 6, 10, 11, 14, 15, 16, 36, 37, 46, and 47. Team 2 encountered several areas with shoulder-high vegetation in the south-central portion of the landfill that were difficult to traverse, documented in photos 8 and 9. Team 1 observed a leaking rubber gasket ("fernco") on the top of well 211A with a visible LFG gas stream escaping, documented in video 2. EPA confirmed with a TVA that the visible gas stream was LFG. Natalie Murray explained that temperature fluctuations between night and day in the fall and spring causes the rubber ferncos to pop out due to building pressure in the wells, and that this is a common occurrence at the landfill. A visible LFG gas stream was also observed coming from a gasket on well 221, EPA took a video (video 3), but the gas stream is not visible in the video. Dave Stefl and Natalie Murray used cell phones to record EPA inspectors for much of the SEM event, including a conversation between Natalie Murray and Inspector Leeds in which Natalie Murray stated that it is Newton County's policy for technicians to never deviate from their pre-determined serpentine path during SEM. Inspector Leeds inquired why inspectors were being recorded and Natalie Murray stated they were instructed to record EPA by upper management. After breaking for lunch, Team 1 took a route along the western quadrant of the landfill accompanied by Dave Stefl. Team 2 took a route along the northeastern portion of the landfill, in cells 9E, 8NE, and 8SE, and were accompanied by Natalie Murray. IDEM Inspector Linscott departed after lunch to attend to a previous commitment. SCS technicians did not return with their IRwins to independently verify exceedances. Natalie Murray expressed doubt that the TVA was an acceptable Method 21 instrument under the rule when exceedances were being verified by EPA after lunch. Inspector Drum asked why the Republic Services team made the decision to leave their team's own IRwins behind but did not receive an answer. Both teams observed additional areas with cracks, erosion, distressed vegetation, and exposed waste, documented in photos 27, 29, 30, 33, and 51. Team 1 observed a large patch of distressed vegetation near well 144A with elevated emissions above 500 ppm. This elevated area was surrounded by shoulder-high vegetation and impossible to see from the outside of the vegetation, documented in photo 53. In total 36 exceedances of 500 ppm methane were found during the SEM survey. Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 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. RECORDS REVIEW 1. Map of existing conditions as of 03-07-24 intermediate cover and excavation areas 2. Map of wells for SEM CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Most recent Design Plan As-Built Map showing vertical and horizontal wells Map of cover (active, intermediate, final) Quarterly SEM reports: 2021-most recent Monthly wellhead readings (initial and adjusted pressure, temperature, gas composition, etc.): 2022-most recent 15-min interval flare flow readings to each flare, the gas treatment plant, and the total GCCS flow from 2022-most recent Monthly cover integrity reports from 2022-most recent Map of serpentine path following during SEM Compliance Assistance: EPA explained that NESHAP Subpart AAAA requires that during SEM, technicians must monitor "where visual observations indicate elevated concentrations of landfill gas, such as distressed vegetation and cracks or seeps in the cover", per 40 CFR 63.1958(d)(1). Concerns: EPA inspectors noted that 36 exceedances of 500 ppm methane were found during the SEM survey, and that the timeline to begin re-monitoring these locations could begin the following day when Newton County received an email from the EPA with the exceedance coordinates. EPA inspectors also informed staff of the leaking fernco on the top of well 211A and of the gas leak on well 221. Environmental managers stated the repairs to these wells were already made by the time of the closing conference. Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 DIGITAL SIGNATURES AILEEN Digitally signed by AILEEN DRUM Date: 2024.08.08 Report Author: _D__R_U__M________1_6:3_4_:14_-_05_'0_0'____________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _F_R__A_N__K_______15_:4_8:_28_-0_5'_00_' _____________ Date: 2024.08.09 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log 2. Appendix B: Field Measurement Data APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Names: Linda Rosen and Emma Leeds Archival Record Location: AECAB Library > Enf_Newton County Landfill_IN_22 > Enf_Newton County Landfill_IN_24_InspRep > Digital Photos Image Log Image Number 1 File Name P6110251.JPG 2 P6110252.JPG 3 P6110253.JPG 4 P6110254.JPG 5 P6110255.JPG 6 P6110256.JPG 7 P6110257.JPG 8 P6110258.JPG 9 P6110259.JPG 10 P6110260.JPG 11 P6110261.JPG Date and Time Description of Image 6/11/2024 10:24 AM 6/11/2024 10:25 AM 6/11/2024 11:08 AM 6/11/2024 12:16 PM 6/11/2024 12:16 PM 6/11/2024 12:19 PM 6/11/2024 12:21 PM 6/11/2024 12:21 PM 6/11/2024 12:24 PM 6/11/2024 12:24 PM 6/11/2024 12:25 PM Inlet taped to IRwin 1 probe Inlet taped to IRwin 2 probe View looking up the south hill from the office parking lot Erosion rills and patchy grass Erosion rills and patchy grass Erosion rills and patchy grass Area with tall vegetation looking down the south hill Area with tall vegetation looking down the south hill Area with tall vegetation Deep cracks and erosion rills Exposed garbage and erosion Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 12 P6110262.JPG 6/11/2024 12:27 PM Location of exceedance A1 13 P6110263.JPG 6/11/2024 12:34 PM Location of exceedance A2 14 P6110264.JPG 6/11/2024 12:43 PM Deep crack 15 P6110265.JPG 6/11/2024 12:46 PM Patchy vegetation 16 P6110266.JPG 6/11/2024 12:47 PM Hole in the ground 17 P6110267.JPG 6/11/2024 12:59 PM Location of exceedance A3 18 P6110268.JPG 6/11/2024 1:03 PM Location of exceedance A3 19 P6110269.JPG 6/11/2024 1:13 PM Location of exceedance A4 20 P6110270.JPG 6/11/2024 1:26 PM Location of exceedance A5 21 P6110271.JPG 6/11/2024 3:25 PM Location of exceedance A6 22 P6110272.JPG 6/11/2024 3:26 PM Leachate cleanout penetration 23 P6110273.JPG 6/11/2024 3:28 PM Location of exceedance A7 24 P6110274.JPG 6/11/2024 3:33 PM Location of exceedance A8 25 P6110275.JPG 6/11/2024 3:43 PM Location of exceedance A9 26 P6110276.JPG 6/11/2024 3:49 PM Location of exceedance A10 27 P6110277.JPG 6/11/2024 3:50 PM Exposed garbage 28 P6110278.JPG 6/11/2024 3:53 PM Location of exceedance A11 29 P6110279.JPG 6/11/2024 3:56 PM Atop the north hill, water accumulation and exposed trash 30 P6110280.JPG 6/11/2024 3:57 PM Atop the north hill, water accumulation and exposed trash 31 P6110281.JPG 6/11/2024 4:08 PM Location of exceedance A12 32 P6110282.JPG 6/11/2024 4:23 PM Location of exceedance A13 33 P6110283.JPG 6/11/2024 4:42 PM Erosion gullies 34 WIN_20240611_12_03_27_Pro.jpg 6/11/2024 12:03 PM Location of exceedance E1 35 WIN_20240611_12_28_46_Pro.jpg 6/11/2024 12:28 PM Location of exceedance E2 36 WIN_20240611_12_29_00_Pro.jpg 6/11/2024 12:29 PM Location of exceedance E2 37 WIN_20240611_12_29_04_Pro.jpg 6/11/2024 12:29 PM Hill with erosion 38 WIN_20240611_12_48_53_Scan.jpg 6/11/2024 12:48 PM Location of exceedance E5 39 WIN_20240611_13_10_09_Pro.jpg 6/11/2024 1:10 PM Location of exceedance E6 40 WIN_20240611_13_13_14_Pro.jpg 6/11/2024 1:13 PM Location of exceedance E7 41 WIN_20240611_13_16_27_Pro.jpg 6/11/2024 1:16 PM Location of exceedance E8 42 WIN_20240611_13_23_42_Pro.jpg 6/11/2024 1:23 PM Location of exceedance E9 43 WIN_20240611_13_29_31_Pro.jpg 6/11/2024 1:29 PM Location of exceedance E10 44 WIN_20240611_13_33_58_Pro.jpg 6/11/2024 1:33 PM Location of exceedance E12 45 WIN_20240611_13_38_50_Pro.jpg 6/11/2024 1:38 PM Location of exceedance E13 46 WIN_20240611_13_40_16_Pro.jpg 6/11/2024 1:40 PM Location of exceedance E14 47 WIN_20240611_13_49_43_Pro.jpg 6/11/2024 1:49 PM Location of exceedance E15 48 WIN_20240611_13_54_12_Pro.jpg 6/11/2024 1:54 PM Location of exceedance E16 49 WIN_20240611_15_31_50_Pro.jpg 6/11/2024 3:31 PM Location of exceedance E17 50 WIN_20240611_15_35_46_Pro.jpg 6/11/2024 3:35 PM Location of exceedance E18 Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 51 WIN_20240611_15_50_03_Pro.jpg 6/11/2024 3:50 PM Location of exceedance E19 52 WIN_20240611_15_58_52_Pro.jpg 6/11/2024 3:58 PM Closer view of photo 53 53 WIN_20240611_15_58_56_Pro.jpg 6/11/2024 3:58 PM Distressed vegetation near well 144A with elevated emissions above 500 ppm surrounded by shoulder-high vegetation 54 WIN_20240611_16_07_55_Pro.jpg 6/11/2024 4:07 PM Location of exceedance E22 55 WIN_20240611_16_57_11_Pro.jpg 6/11/2024 4:57 PM Location of exceedance E23 Video Log Video Number 1 File Name WIN_20240611_12_38_45_Pro.mp4 Date and Time 6/11/2024 12:38 PM Description of Video Location of exceedance E4 2 WIN_20240611_12_40_17_Pro.mp4 6/11/2024 12:40 PM Exceedance E4 visible gas stream 3 WIN_20240611_12_47_50_Pro.mp4 6/11/2024 12:47 PM Exceedance E5 4 WIN_20240611_12_48_16_Pro.mp4 6/11/2024 12:48 PM Exceedance E5 APPENDIX B: FIELD MEASUREMENT DATA Calibration Data and Instrument Information Instruments were calibrated by Sasa Dunovic and Giles Chickering. Instrument Information Instrument Inficon IRwin #1 (S/N:92004352) Inficon IRwin #2 (S/N:92004350) Thermo Fischer TVA 2020 #B39303 Thermo Fischer TVA 2020 #B39302 EPA Inspector Aileen Drum Emma Leeds Sasa Dunovic DeMarkus Hodge Calibration Gas Information Calibration Gas Composition Air zero grade Methane in air 503.1 ppm Methane in air 1960 ppm Methane in air 10000 ppm Lot Number 1486172 304-402518883-1 304-402110299-1 304-402110298-1 Expiration Date 05/2026 08/15/2026 05/11/2025 05/11/2025 Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 TVA Bump Check Post Calibration at 9:45 AM TVA Reading for 503.1 ppm gas TVA # B39303 496 TVA # B39302 494 Reading for 1960 ppm gas 1963 1948 Reading for 10000 ppm gas 9412 9720 IRwin 1 (S/N: 92004352) Calibration at 10:00 AM Measurement Reading for 503.1 ppm gas #1 497 #2 497 #3 498 Response Time (s) 4 4 4 IRwin 2 (S/N: 92004350) Calibration at 10:00 AM Measurement Reading for 503.1 ppm gas #1 488 #2 486 #3 485 Response Time (s) 3 2 2 Bump Check after Mid-Day Recalibration Instrument Reading for 503.1 ppm gas TVA # B39303 501 TVA # B39302 502 Inficon IRwin #1 500 (S/N:92004352) Inficon IRwin #2 500 (S/N:92004350) Background Concentrations Instrument TVA 2020 #B39303 IRwin #2 Upwind x 0ppm Downwind 5ppm average x Surface Emissions Monitoring Data Exceedance measurements from US EPA SEM Survey Exceedance Reading Confirmation Location Field Notes ID Reading A1 709 1374 Well 166A Phase 8B A2 724 4060 Distressed vegetation- staff says maybe phase 6A but unsure latitude 40.930813 40.930748 longitude -87.345125 -87.344954 Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 A3 536 2300 Gully on north slope 40.931488 -87.344825 A4 574 1056 Gully on slope by well 126 40.930684 -87.344193 A5 706 1050 At cleanout penetration, north 40.930796 -87.343304 slope east of well 24 by approx. 50 ft A6 796 674 Well 306 40.936299 -87.336783 A7 1756 1352 By crack 40.936318 -87.336835 A8 1056 1756 Well 299 40.936431 -87.337494 A9 540 1071 North of well 293 by about 20 ft 40.936968 -87.33797 A10 1559 1712 40.93726 -87.337808 A11 2967 6028 Well 286 40.937444 -87.337739 A12 1043 2012 30 feet from well 291 40.936838 -87.336426 A13 2545 2737 Entrance to north hill 40.937235 -87.33562 E1 5027 1.60% Well 129 C 40.929923 -87.341539 E2 618 1200 Exposed area 40-50 ft NE corner 40.930589 -87.339859 downhill E3 758 800 EW-226A 40.930925 -87.339257 E4 798 802 Fernco on well top leaning, 40.930944 -87.337756 visible gas stream on well 211A E5 1205 1205 Well 221, visible stream of gas 40.931002 -87.338496 coming out of gasket E6 556 1000 50 ft south of TLS 16 40.931903 -87.335948 E7 748 1500 Well TLS 16 & surrounding 3 ft 40.932036 -87.335958 radius E8 933 2000 Well TLS 17 and TLS 18 40.932267 -87.335587 E9 2232 3000 Well 205 all around base 40.93143 -87.335694 E10 1681 2000 TLS 28, leaking air line 40.930461 -87.335685 E11 844 1500 140A well 40.929954 -87.335837 E12 891 1700 40 ft SE of well 140A 40.929776 -87.33579 E13 600 800 GW-139, dent around base 40.92938 -87.335725 E14 979 1200 Erosion, 40 ft SW of GW 139 40.929234 -87.335908 E15 643 864 EW-134, tires at base 40.928487 -87.337792 E16 551 1500 5 ft W of well HTC 08 & HTC12/ 40.92851 -87.338626 Well 200 E17 511 1700 Leachate cleanout line, dead 40.932592 -87.350987 grass on NW corner E18 571 1700 Between 2 leachate cleanouts, 40.932475 -87.350649 60 ft east of E-17 E19 518 1500 Dead vegetation/ erosion, 60 ft 40.932352 -87.348805 east of GW 33A E20 880 810 Well 144 A 40.932476 -87.34843 E21 3132 2000 HT-01, 15 ft north of 144A 40.932499 -87.348429 Facility Name: Newton County Landfill Facility Location: 2266 E 500 S Brook, IN 47922 Date of Inspection: June 11, 2024 E22 659 1100 L5-11 at edge of bentonite 40.932717 -87.347319 repair E23 525 1500 SW of well 29A 40.931974 -87.351447 *Exceedances A1-A13 were measured with IRwin #1 and confirmed with TVA #B39303. Exceedances E1-E23 were measured with IRwin #2 and confirmed with TVA #B39302. Map of GPS Path and Exceedances The blue path was taken by Emma Leeds, DeMarkus Hodge, and Giles Chickering with IRwin #2 and TVA #B39302. The green path was taken by Aileen Drum, Sasa Dunovic, and Linda Rosen with IRwin #1 and TVA #B39303. Red points indicate locations where methane measurements exceeded 500 ppm.