Document jy65eY0MNvv1JDJ3vVa57DZgN

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 CLEAN AIR ACT INSPECTION REPORT Waste Management Deer Track Park Landfill, Watertown, WI Daniel Heins, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Waste Management Deer Track Park Landfill, Watertown, WI Facility Location: N6756 Waldmann Lane, Watertown, WI 53094 Date of Inspection: On Site Inspection: June 21, 2021 Virtual Conferences: June 22, 2021 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist 2. Vicky Mei, Environmental Engineer 3. Joshua Hufferd, Environmental Engineer 4. Brianna Fenzl, Environmental Engineer 5. Brittany Cobb, Environmental Engineer (virtual conference only) Other Attendees: 1. Dan Leclair, Environmental Engineer - Waste Management (WM) 2. Joe Hackbarth, District Manager - WM 3. Kyle Kneser, Area Gas Operations Manager - WM 4. Jeff Krall, Area Gas Operations Manager - WM 5. Kyle Badtke, Gas Operations Supervisor - WM 6. Khaled Mahmood, Consultant - Tetra Tech 7. Tami Sands, Consultant - Tetra Tech Contact Email Address: dleclaire1@wm.com Purpose of Inspection: To determine Clean Air Act (CAA) compliance and perform a comparative Surface Emissions Monitoring (SEM) survey Facility Type: Muncipal solid waste (MSW) landfill Regulations Central to Inspection: 40 C.F.R. Part 60, Subpart WWW; 40 C.F.R. Part 63, Subpart AAAA, Title V Permit Requirements On Site (6/21) Arrival Time: 10:45 On Site (6/21) Departure Time: 16:30 Virtual Conference (6/22) Start Time: 10:00 Virtual Conference (6/22) End Time: 12:00 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 Waste Management representatives. Process Description: Deer Track Park Landfill ("the Landfill") is an MSW landfill that has operated since the 1970s. The whole landfill is lined, as the old waste was flipped onto an installed post-Resource Conservation and Recovery Act (RCRA) Subtitle D liner. The Landfill's planned footprint is approximately 112 acres, with 14 acres pending waste. Presently, 64 acres are capped and under final cover, largely covering the northeast lobe of the site. The Landfill receives 700 to 800 tons of waste per day, which is placed on the southwest face of the site. Approximately 61% of the waste is MSW, 28% alternate daily cover (ADC), and the rest split between sludge, construction & demolition waste, and any other special wastes. ADC includes shredder fluff and contaminated soils. If the contaminated soils are laden with volatile organic compounds (VOC), they are passively treated by adding fertilizer and allowing microbial breakdown. WM tests these soils to confirm when they reach a low enough organic content to use as cover. The Landfill does accept asbestos waste. The design capacity is 12.8 million cubic yards, including the ADC. The expected remaining lifespan is 10-15 years, pending the projections from the collections from the former Advanced Disposal Services fleet now that it has been acquired by WM. No expansion is currently planned. Page 2 of 6 Leachate is collected above the liner with pipes/sumps, which go to tanks for storage. In 2020, the site produced 8.5 million gallons. There are several tanks on site for storing leachate, from 25,000 to 30,000 gallons. Leachate is sent to neighboring publicly owned treatment works (POTWs), primarily the Atkinson POTW. The Landfill checks liquid levels in wells annually. If a well is more than 50% obstructed, the Landfill will determine if the well needs a pump. Basis for evaluation includes determination if the well is vacuum limited, surface emissions monitoring hits, and gas quality. Presently, 13 wells have operating pumps, and there are additional wells with stuck non-operational pumps. There is no set standard to determine if a well must have a dewatering pump added. Pumps are checked on a monthly basis to determine if they are functioning. If not, they may be flagged for cleaning or replacing. To determine if a broken or obstructed well needs replacing, the Landfill uses the same criteria as for determining if a pump is needed. The Landfill has 72 vertical wells, 16 horizontal wells, and 11 cleanout risers. Currently, the Landfill installs horizontal wells into areas of waste placement every 30 to 40 feet, instead of the previous practice of installing vertical wells and extending them. When the area reaches final grade, the Landfill then installs vertical wells. Pending gas quality and collection efficiency, the horizontal wells may be either retired or kept in service. Collected landfill gas (LFG) is primarily routed to a gas to energy plant with eight Caterpillar engines. The landfill also has a candlestick flare as a backup control. Staff Interview: The Landfill has only just started testing total sulfur content of their LFG as per their upcoming permit renewal, and has not seen sulfur content issues. They test the engines every five years for formaldehyde emissions. Gas generation has been declining, so the Landfill typically is only running six of their eight engines. In 2020, the candlestick flare operated for approximately six hours. The gas blower was installed in the range of 2005 to 2007. The Landfill does not have any formal odor monitoring program, just informal response to complaints if they happen. Cover integrity monitoring is conducted by wellfield technicians. Issues are recorded, and corrective actions determined. Corrective actions may be delayed due to safety or weather concerns. For surface emissions monitoring (SEM), the closed section of the landfill is only monitored on an annual basis (with Wisconsin Department of Natural Resources approval), after having demonstrated a lack of SEM exceedances over at least four consecutive quarters. Until first quarter of 2021, SEM was conducted in-house with an RKI Eagle 2. The site began monitoring penetrations 5 or 6 years ago. Starting in the second quarter of 2021, the Landfill started using Sniffer Robotics to conduct monitoring using the consultant's ground crews with a Elkins Earthworks device. They do not use Sniffer's drone package. Page 3 of 6 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA conducted comparative surface emissions monitoring on the landfill. EPA found 18 points in exceedance of 500 ppm, particularly concentrated along the slope directly above the haul road. EPA observed distressed vegetation and strong odors of landfill gas. Exceedances were found both at wellheads and on the general surface of the landfill. EPA observed bentonite seals having dried out and pulled away from penetration points, resulting in leaking gas. Photos and/or Videos: were taken during the inspection. See Appendix A. Field Measurements: were taken during this inspection. See Appendix B. RECORDS REVIEW Requested and reviewed prior to inspection: Current map of the GCCS Current map of showing final cover, intermediate cover, and working face of the landfill Current map of the leachate collection system 2 years of SEM reports, with all associated recorded data and documentation of correction of exceedances 4 most recent semi-annual reports Past year of depth to water measurements for each well with percent of perforation in operation, in a spreadsheet format (most recent data if not monitored in past year) Most recent 12 months of cover integrity reports Past year of wellhead parameters monitoring (in spreadsheet format), including records for correction of any exceedances CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Past 5 years of SEM reports & semi-annual reports o Aside from previously received reports Current GCCS design plan Most recent performance test for the turbines Past year of control device parameter monitoring (e.g. temperature and LFG flow to flare), in a spreadsheet format Page 4 of 6  Waste accepted by category over the past year, in a spreadsheet format Most recent sulfur test results Years of install and make/model for the engines, flare, and blowers Water level/pumps SOP Past year of pump maintenance/cycle records DNR approval of annual SEM monitoring for the closed section SOP on liquid addition/recirculation/'softs' Past 5 years annual waste reports Documentation of correction and re-monitoring to the exceedances EPA detected 2021 Second Quarter SEM report DIGITAL SIGNATURES DANIEL Digitally signed by DANIEL HEINS _H_E__IN__S________D17a_:t1e_8::21_01_2-10_.50'_80.01_'9____________ Daniel Heins, Report Author NATHAN Digitally signed by NATHAN FRANK _F_R__A_N__K_______D15a_:t1e_4: :2_500_2-10_.50_'80.02_'0_____________ Nathan Frank, Section Chief (IL/IN) Page 5 of 6 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Field Measurement Data, Including Maps Page 6 of 6 Facility Name: Deer Track Park Landfill Facility Location: N6756 Waldmann Lane, Watertown, WI 53094 Date of Inspection: June 21 & 22, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Daniel Heins & Vicky Mei 2. Archival Record Location: ERC Enf_DeerTrackWM__WI_InspRep Image Number A1 B20 B21 B22 B23 B24 B25 B26 B27 B28 File Name IMG_0001.jpg IMG_0324.jpg IMG_0325.jpg IMG_0326.jpg IMG_0327.jpg IMG_0328.jpg IMG_0329.jpg IMG_0330.jpg IMG_0331.jpg IMG_0332.jpg Date/Time (Central) 15:45 14:41 14:53 14:56 14:59 15:08 15:10 15:12 15:18 15:25 Description of Image Exceedance to LRT 14. Exceedance dead veg Exceedance Exceedance Exceedance Exceedance Exceedance Exceedance Exceedance Exceedance location at uphill upslope from fill in trench by road in trench by road in trench by road in trench by road in trench by road in trench by road by GW-57 by pile of dirt of haul road, area road by on path fence, Appendices Page 1 of 3 Facility Name: Deer Track Park Landfill Facility Location: N6756 Waldmann Lane, Watertown, WI 53094 Date of Inspection: June 21 & 22, 2021 APPENDIX B: FIELD MEASUREMENT DATA Latitude 43.090383 43.090543 43.090464 43.090834 43.091754 43.09141 43.090996 43.090109 43.089845 43.090857 43.090843 43.09074 43.090799 43.090335 43.090312 43.09025 43.090276 43.090788 Longitude -88.745029 -88.744781 -88.746248 -88.744079 -88.744717 -88.745677 -88.745689 -88.744353 -88.744117 -88.747136 -88.747454 -88.74714 -88.747289 -88.746179 -88.746079 -88.74593 -88.745756 -88.745095 Location Description & Notes Haul road, east of bio pile Well 56 (in between vacuum lines), dry bentonite Uphill of haul road, on path to LRT 14 (distressed vegetation) Well 54 150' upslope GW50 GW52 (had flag from prior week's survey) Bio pile - oil contaminated soils GW55 Cleanout 49 150' upslope from fill area road by fence, dead veg Dead veg, trench by road by fill area Trench by fill road Trench by fill road Trench Trench Trench By GW 57 Pile of dirt #A56575 800 1400 2600 1400 800 900 2400 1100 600 700 1100 800 1000 1400 #A56584 800 600 898 600 700 550 8000 6000 600 1000 1500 700 1000 1200 WM Reading 260 8000 2200 800 810 Confirmed Initials SH WH KB KK SH KK KB KK, SH SH, KK SH SH KK, KB KK DL JH KB KB KB Pic # A1 B20 B21 B22 B23 B24 B25 B26 B27 B28 Calibration and Instrument Information EPA used two ThermoFisher Toxic Vapor Analyzer (TVA) 2020 instruments to conduct Method 21. TVA #A56575 Methane Reading (ppm) # 1 498 # 2 495 # 3 497 Response Time (s) 4.82 4.45 5.09 TVA #A56584 Methane Reading (ppm) 498 497 497 Response Time (s) 4.89 4.00 4.47 EPA calibration gases: Air, zero grade, THC < 1 ppm, expiration 05/2026 Methane 500 ppm in air, expiration 05/2025 The downwind background concentration was recorded at 3.8 ppm. Appendices Page 2 of 3 Facility Name: Deer Track Park Landfill Facility Location: N6756 Waldmann Lane, Watertown, WI 53094 Date of Inspection: June 21 & 22, 2021 Map of Detected Hits SEM hit locations plotted over satellite imagery from April 1, 2021 as depicted on Google Earth. Appendices Page 3 of 3