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Report Title: Inspection Date(s): Regulatory Program(s): Clean Air Act Inspection of Prince William County Sanitary Landfill 03/18/2025 - 03/19/2025 SIP, NSPS, NESHAP Company Name: Facility Name: Facility Location: Latitude: County/Parish: Prince William County Prince William County Sanitary Landfill 14811 Dumfries Rd Manassas, VA 20112 38.634597 Longitude: Prince William County -77.428519 AFS/ICIS-Air Number: Permit Number: NAICS Code: DSB ID #: VA0000005115300139 NVRO72340 562212 SIC: ECAD-76 4953 Facility Representatives*: Point of Contact Tammy Gumbita, Senior Environmental Program Manager Phone: 703-792-6804 Email: tgumbita@pwcgov.org Trent Magill, Principal Engineer Phone: 703-568-5144 Email: tmagill@pwcgov.org *Additional facility representatives identified in report body and/or on attached sign in sheet EPA Inspectors*: Alex Everhart, Life Scientist, 3ED21 Phone: 215-814-2114 Email: Everhart.Alex@epa.gov Parmatma Adhikari, Environmental Engineer, 3ED21 Phone: 215-814-2161 Email: Adhikari.parmatma@epa.gov *Additional inspectors identified in report body and on attached sign in sheet State/Local Inspectors*: Paul Foxwell, Air Compliance Inspector, VA DEQ Phone: 703-587-2606 Email: paul.foxwell@gdeq.virginia.gov DSB ID #: ECAD-76 EPA Lead Inspector Signature Supervisor Signature Alex Everhart 1600 John F Kennedy Blvd Philadelphia, PA 19103-2852 KRISTEN HALL Digitally signed by KRISTEN HALL Date: 2025.05.15 07:17:06 -04'00' Kristen Hall Date Date 2 DSB ID #: ECAD-76 Table of Contents I. Introduction ............................................................................................................................. 4 A. Summary of the Facility ....................................................................................................... 4 B. Inspection Opening Conference .......................................................................................... 5 II. Observations ........................................................................................................................... 5 III. Site Activity/Process Description..........................................................................................10 IV. Records Review .................................................................................................................... 12 V. Closing Conference ............................................................................................................... 15 VI. List of Attachments .............................................................................................................. 16 3 DSB ID #: ECAD-76 I. Introduction The United States Environmental Protection Agency (EPA) conducted a Clean Air Act (CAA) inspection at Prince William County Sanitary Landfill (PWCSLF or Facility) to verify compliance with applicable State and Federal regulations. The Virginia Department of Environmental Quality (VADEQ) was notified of the inspection on March 3, 2025, via email. On March 17, 2025, EPA notified the Facility of the planned inspection via phone and email. EPA emailed a list of records for review to Tammy Gumbita, Senior Environmental Program Manager, prior to the inspection (see Attachment 1). These records are listed in the Records Review section of the report. The inspection included an evaluation of the Facility's processes and its compliance with the CAA. All information included in this report is the result of statements by the Facility representatives, materials shown to the inspectors by the Facility representatives, and/or documents provided by the Facility representatives to the inspectors at the time of, or subsequent to, the inspection. In addition, information gathered prior to the inspection from a review of EPA and State records may be included in Section A. Summary of the Facility. A. Summary of the Facility The Facility is located at 14811 Dumfries Rd, Manassas, VA 20112 and is publicly owned and operated by Prince William County. The PWCLF has an active Gas Collection and Control System (GCCS) connected to a blower that pulls a vacuum on the landfill to recover the landfill Gas (LFG). The Facility received a Title V operating permit (NVRO72340) from VADEQ on February 9, 2004, and subsequently expired on April 14, 2007. The Facility received a Stationary Source Permit to Operate implementing the requirements for Reasonably available Control Technology for the PWCSLF on April 16, 2004. The Facility received a Minor New Source Review Permit on November 18, 2022, that was subsequently amended on June 6, 2023. The PWCSLF is categorized as a major source of carbon monoxide (CO) emissions and a minor source for all other criteria pollutants. The Facility is subject to, or potentially subject to the following federal regulations: 40 CFR Part 63: Subpart AAAA - National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills 40 CFR Part 60: Subpart Cf - Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills 40 CFR 60: Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR 61: Subpart M - National Emission Standard for Asbestos 40 CFR Part 60: Subpart WWW - Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification on or After May 30, 1991, but Before July 18, 2014 4 DSB ID #: ECAD-76 40 CFR Part 60: Subpart XXX - Standards of Performance for Municipal Solid Waste Landfills That Commenced Construction, Reconstruction, or Modification after July 11, 2014 40 CFR Part 63: Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines B. Inspection Opening Conference At 08:30 AM on March 18, 2025, EPA inspectors arrived at the Facility for a CAA Inspection and conducted a brief opening conference. PWCSLF was represented by Tammy Gumbita, Senior Environmental Program Manager; Trent Magill, Principal Engineer; Jason Martin, Opal Fuels Wellfield Supervisor; and Dana Whitcomb, Opal Fuels Area Manager. Also, present from VADEQ was Paul Foxwell, Air Compliance Inspector. EPA inspectors, Alex Everhart, Parmatma Adhikari, Owen Ehret, and Ed Owens, presented their credentials and identification and explained the purpose of the visit was to conduct a CAA inspection to determine compliance with their permit and any applicable regulations. Additionally, EPA informed the facility representatives of their right to claim any confidential business information (CBI). At that time, Ms. Gumbita did not claim any photos or documentation as CBI. EPA Inspectors explained to the Facility that the inspection would include an opening meeting, a facility walkthrough, and a records review. The Facility was also informed by EPA inspectors that during the walkthrough, photographs would be taken, and that comparative surface emission monitoring (SEM) would be performed using either an Inficon IRwin (IRwin) Methane Leak Detector or a Toxic Vapor Analyzer TVA2020. EPA informed the Facility that immediately following the opening conference EPA inspectors would be performing SEM at the landfill listed in the Facility's Title V permit. All SEM equipment was calibrated the morning of March 18, 2025, prior to arriving onsite. Records of the calibrations are included as an attachment to the Inspection Report. The opening conference concluded at 8:50 AM. All responses provided throughout the remainder of the Inspection Report were provided by the Facility personnel identified in the opening conference unless otherwise stated. II. Observations Day 1 March 18, 2025 Immediately following the opening conference at 08:50 AM on March 18, 2025, EPA inspectors (Alex Everhart, Parmatma Adhikari, Owen Ehret, and Ed Owens) were taken to the Landfill by Prince William County Sanitary Landfill contractor, Jason Martin (Opal Fuels Wellfield Supervisor), to take upwind and downwind methane readings with the Inficon (IRwin) methane detector prior to starting the SEM. A measurement of one (1) parts per million (ppm) was recorded upwind and one (1) ppm was recorded downwind. The Facility indicated that waste in all Phase III Cell A was not older than five years and was 5 DSB ID #: ECAD-76 not at final grade. Given the age of waste in those cells EPA did not include Phase III Cell A as part of the comparative SEM. EPA inspectors began the comparative SEM 9:28 AM on the Phase I Sequence 3 Cap. The image below shows the path taken while completing comparative SEM. 6 DSB ID #: ECAD-76 There were 23 detections in exceedance of the 500-ppm regulatory limit, as defined in 40 CFR 60.34f(d). The following table summarizes the readings in exceedance of the 500-ppm regulatory limit: 7 DSB ID #: ECAD-76 The SEM and Day 1 of the inspection concluded at 4:09 PM on March 18, 2025. Day 2 March 19, 2025. On Day 2 (3/19/25) of the inspection at 8:00 AM EPA (Alex Everhart, Parmatma Adhikari, Owen Ehret and Ed Owens) met with PWCSLF Representatives (Tammy Gumbita and Trent Magill) to continue the Facility tour. The inspection team was first led to the Renewable Natural Gas (RNG) Facility that is operated by Opal Fuels. The inspection team was met by the RNG Plant Operator Hoover Dickenson. Mr. Dickenson stated that Opal Fuels has had an agreement with PWCSLF since the 1990s to handle all aspects of compliance related to landfill gas. Mr. Dickenson described the RNG facility process as follows: 1. Landfill gas is pulled via a blower where it enters a media-based hydrogen sulfide (H2S) treatment system, 2. After H2S treatment the landfill gas is cooled and moisture is removed from the landfill gas, 3. The landfill gas then moves to the next stage of treatment where it goes through an Air Liquide skid to remove impurities and carbon dioxide, 4. Next nitrogen is removed in the nitrogen removal unit (NRU) 8 DSB ID #: ECAD-76 5. The product gas is then goes to the "virtual pipeline" where it is loaded into tractor trailers 6. Waste gas from each step of treatment is routed to the thermal oxidizer (TOX) Mr. Dickenson also stated that the TOX (PCD-08) only burns waste gas, and the candlestick flare (PCD09) burns treated off specification gas and untreated gas in the event of a shutdown at the RNG facility. He stated that both the PCD-08 and PCD-09 have continuous natural gas pilot lights. The natural gas for the pilots is currently trucked in and stored in tanker trucks until the natural gas pipeline construction is complete and the Facility is connected to the pipeline allowing the pilots to be connected to the pipeline. He stated that temperatures from the PCD-08 and PCD-09 are continuously recorded, and that Opal provides all of the data to PWCSLF. He stated that the initial and only performance test that have been completed on PCD-08 and PCD-09 happened in 2024. Mr. Dickenson stated that the goal of the RNG plant is to fill 10 to 12 tractor trailers per day until the facility is tied into the actual pipeline. He stated completion of the actual pipeline is eight to twelve months away. At the time of inspection, the 3255 SCFM of LFG was entering into the RNG facility at 51% methane (CH4) and the product gas was 98% CH4. He stated the overall capacity of the RNG facility is 6,500 standard cubic feet per minute (SCFM). Following a verbal description of the process, Mr. Dickenson led the EPA inspection team on a tour of the RNG facility. The inspection team began outside at the two blowers which pull the LFG from the landfill and followed the path of the LFG. The EPA inspection team observed the H2S treatment vessels and cooling skids. The EPA inspection team then proceeded inside where the LFG enters the Air Liquide unit and the route to the NRUs that are located outside of the building was observed. The EPA inspection team moved outside and observed the series of NRUs, each NRU was equipped with pressure relief valves that vent directly to the atmosphere. Mr. Dickenson stated that these were present in the event of a pressure spike but that can also be utilized to purge the system after a shutdown as well if needed. The inspection team then moved through the parking lot and observed the TOX and PCD-09. The flow to the TOX at the time of inspection was 1234 SCFM and the destruction temperature was 1794 F. Gas was not being burned in PCD-09 at the time of inspection. The inspection team was then led by Prince William County personnel to the Flare Yard which contained flares PCD-10 and PCD-03. Both flares are used as needed to bur gas not taken by the RNG facility either because of a plant shutdown or due to production of more landfill gas than the RNG plant can utilize. Neither of the flares were in operation at the time of inspection. PCD-10 has a rated capacity of 2100 SCFM and PCD-03 has a rated capacity of 4700 SCFM. The inspection team was then taken into the buildings that previously held five (5) generators that utilized landfill gas. The inspection team verified that the emission sources PCD-10, PCD-02, PCD-05, PCD-06 and PCD-07 had been removed from the Facility. The inspection team was then led to flare PCD-04. The flare was not operating at the time of inspection. The facility indicated that the flare serves as a backup and can only pull landfill gas from a portion of the landfill. On average, the flare operates about once a month for maintenance. 9 DSB ID #: ECAD-76 The inspection team was then led to the scale house where an emergency generator was observed. The generator is powered by a 3.0 Liter 60-kilowatt, Model 5030TF270C, John Deere diesel powered engine. At the time of the inspection the hour meter read 501.3 hours. The generator had a preventative maintenance log on the generator, and it indicated, the two most recent preventative maintenance events were completed 10/13/23 and 1/19/24. The inspectors then moved to the fleet building which is collocated with the landfill. The Facility stated that landfill equipment along with other County equipment is maintained at the fleet building. The inspection team was taken on a tour of the Fleet facility by the Fleet Administrator Brent Lineberger. Mr. Lineberger stated that their Fleet building has one (1) emergency generator. The inspection team observed one 180 kilowatt Generac 2000 Series generator. The hour meter at the time of inspection indicated 216.1 hours of operation. The inspection team was then taken through the shop bays where the following were observed: One (1) SkatBlast blast cabinet that utilizes glass beads as the blasting media One (1) Millermatic 250P MIG welder One (1) Millermatic 210 MIG welder One (1) parts washer that utilizes "Safe wash SW-4" The facility tour ended at 12:15 pm on March 19, 2025. III. Site Activity/Process Description Day 2 March 19, 2025 On Day 2 (3/19/25) of the inspection at 12:20 EPA (Alex Everhart, Parmatma Adhikari, Owen Ehret and Ed Owens) and VADEQ inspector (Paul Foxwell) met with PWCSLF Representatives (Tammy Gumbita and Trent Magill) to discuss the Facility process and continue the inspection. PWCSLF is publicly owned and operated by Prince William County. The normal hours of operation are from 6:00 AM to 6:00 PM Monday to Friday and Saturday 8:00 AM to 5:00 AM. There are approximately 80 full time employees. The property was originally developed as a landfill owned by Prince William County and has remained a landfill since its initial development. The total footprint of the Facility is approximately 1,062 acres of which 165 acres are permitted as landfill. The Facility began operations in 1966 as a "dump" which was subsequently closed in 1971. Currently the closed area is used as a ballfield. The landfill was first permitted in 1971 and began operations in 1972. In 1991, Phases I-III were permitted as Subtitle D lined landfill phases consisting of a synthetic base liner. The current total design capacity of the landfill is 16.157 million Megagrams. Based on the Facilities most recent capacity report, Phases I-III are expected to reach capacity in April 2034. Unpermitted Phase 4 has an additional estimated 30 to 40 years of life remaining. The Facility has a has a daily maximum disposal limit of 2275 tons of waste. The facility accepts mainly household waste and most construction and demolition debris is diverted to other landfills. The landfill 10 DSB ID #: ECAD-76 does not accept Asbestos. Clean Harbors collects and removes all Household Hazardous Waste (HHW) at the Facility. PWCSLF generates approximately 55 million gallons of leachate and landfill gas system condensate per year. Leachate from the Facility discharges to either the one (1) leachate lagoon or via direct discharge connection to a wastewater treatment plant. All leachate from PWCSLF is sent to either the HL Mooney or Prince William County Wastewater Treatment Plant. A fleet maintenance shop is collocated with the Landfill. The facility stated that no fabrication work or painting occurs in the maintenance shop. It is used for completing preventative maintenance and minor repairs on equipment. The facility stated that waste oil is burned onsite in waste oil heaters used for comfort heat in the maintenance shop. PWCSLF stated that only minor welding occurs. The following two (2) reciprocating internal combustion engine (RICE) sources are present at the Facility; however, neither are included in the facility's Title V permit: Scale house emergency generator o Compression ignition, 3.0 Liter 60-kilowatt, Model 5030TF270C, John Deere Fleet shop emergency generator o Compression ignition, 7.5 Liter 180 kilowatt Generac 2000 Series generator The facility originally installed it's GCCS in the 1990s. The latest expansion to the GCCS was ongoing at the time of inspection, it included redrilling of 15 wells and installing four (4) new wells. PWCSLF stated that the GCCS has been installed in accordance with the approved Design Plan. The Facility stated that they typically expand the system every six months. The system currently has a design capacity of 6,500 standard cubic feet per minute (SCFM). There are currently 171 LFG collectors installed, PWCSLF was unsure of the breakdown of vertical/horizontal LFG wells and collectors connected to the leachate system. A number of the LFG collectors, have pumps in them for dewatering the LFG wells; however, the Facility was unsure of how many had pumps installed. The liquids from the LFG wells are pumped into sumps of the where it is pumped into the leachate system. The Facility stated that LFG from the GCCS system comes into the Knockout Pot (KOP) from the landfill header, where free liquids fall out. The gas then flows through the blowers. The blowers maintain the vacuum set point on the wellfield of approximately 60 inches of water. The gas then goes to a "Y" where it is sent via pipe header where it is directed to one of the following: PCD-03 PCD-04 PCD-10 RNG Facility Source Description Candlestick Flare Candlestick Flare Candlestick Flare Energy Developer Notes Max Flow 4,700 SCFM Max Flow 1,000 SCFM Max Flow 2,100 SCFM System Capacity 6,500 SCFM The Facility began operations of a gas to energy engine plant in 1995. The two original engines were replaced in 2006, and then three more engines were added in 2013. The engine plant remained in 11 DSB ID #: ECAD-76 operation until December 2023 when it was shut down in preparation of bring the RNG plant online. The RNG plant became operational in May of 2024. Opal Fuels is contracted by Prince William County to operate all aspects of the GCCS, however; Prince William County remains responsible for submitting all compliance reports. Opal Fuels completes all the required monthly Operations and maintenance for the GCCS as well as the quarterly SEM. IV. Records Review Day 2 March 19, 2025 The records review commenced immediately after the facility/process description on March 19, 2025, at 1:20 PM. EPA inspectors reviewed documents requested in the March 17, 2025, email to Ms. Gumbita (see Attachment 1). Some records were provided at the time of the inspection by Ms. Gumbita; however, Ms. Gumbita agreed to provide the remainder of the records after the inspection. Below are the records requested and what was provided: 1. General maps: o Map with cover types, include descriptions of the cover A hard copy of this was provided during the inspection. o Landfill cell map and year of first waste placement for each cell A hard copy of this was provided during the inspection. 2. Flares & controls o Flare monitoring data (2022-present) This information was to be provided electronically but has not been provided yet. o Flare Performance tests (2022-present) The 2024 Performance test report for PCD-08 and PCD-09 was reviewed during the inspection. o Collected gas flow (2021-present), (ideally 15-minute granularity, if data is saved at higher granularity that is fine too, if it is not kept at that granularity than the most granular form of that data) This information was to be provided electronically but has not been provided yet. 3. GCCS Design Plan o Current plan & approval (if applicable) 2024 Design plan and approval was provided during the inspection. 4. GCCS o Map of GCCS as built This information was provided during the inspection. o If horizontal wells are used to control areas under NSPS/NESHAP collection requirements, a description of the spacing (vertical and horizontal) and a map of the extent of the collectors This information was to be provided electronically but has not been provided yet. o Table of wells active at any point 2021-present 12 DSB ID #: ECAD-76 Drill / decommission dates as applicable (if well was installed pre-2021, drill date not needed) Well type (horizontal, vertical etc) Location of well (ideally lat/lon but otherwise identify what coordinates are used) Depth of well & depth to perforation This information was to be provided electronically but has not been provided yet. o Wellhead monitoring and records of tuning (2021-present) Include methane, hydrogen, CO, and flow rate, if available This information was to be provided electronically but has not been provided yet. o Any wellhead HOVs approvals relevant for 2021-present, along with approvals of any alternative timelines or corrections in that time. The Facility stated there are no HOVs for the Landfill. o Any monitoring of liquid depth in wells (2021-present), including identification of % of perforation obstructed Identification of wells with dewatering pumps Descriptions of any SOPs or internal guidelines that may exist relating to well dewatering This information was to be provided electronically but has not been provided yet. 5. Annual/semi-annual reports - for 2022 to present, all: o NSPS/NESHAP/EG semi-annual reports This information was to be provided electronically but has not been provided yet. o Air permit compliance reports This information was to be provided electronically but has not been provided yet. o SSM reports This information was to be provided electronically but has not been provided yet. o Annual Emission reports The 2022 and 2023 Annual Emission reports were reviewed during the inspection. 6. SEM - for 2022 to present: o Include the most recent SEM reports, or at least as much of it as has been completed even if they are not a part of any final semi-annual o All recorded data GPS track of path taken Readings including non-exceedances o Records of corrective actions Approvals of any alternatives to expansion of the GCCS or alternative timelines o Any guidance or training materials provided for the SEM technicians o Explanation for why any areas were not monitored, when applicable The 2022 SEM reports were presented during the inspection no exceedances were reported. 7. Cover integrity - for 2022 to present: o Any records of the monthly cover integrity monitoring and associated corrective actions This information was to be provided electronically but has not been provided yet. 13 DSB ID #: ECAD-76 8. Air permits: o All air permits active for the site in the past five years and their applications The Facility provided copies of the approved 2002 Title V permit and June 6, 2023 NSR Permit. 9. Part 98 o Part 98 Greenhouse Gas Report (2022-present) The 2022 and 2023 Reports were reviewed. The facility reported 22.7 metric tons of CO2 in 2022 and 36.9 metric tons of CO2 in 2023 o If the landfill changed the method for calculating emissions in the primary report from Equation HH-6 to Equation HH-8 in the rule (or vice versa), or is reporting using the lower estimate of the two equations, provide an explanation of the basis for that decision Not Applicable 10. Annual waste deposited tonnages by type from 2022 to present o Include a list of the primary sources of industrial wastes and a description for any special wastes listed o Outline of what wastes (if any) are classified as non-degradable for LandGEM maximum expected gas generation (Design Plan) along with the basis for this classification o Outline of what wastes are classified as "inert" if applicable for Part 98 reporting along with the basis for this classification This information was to be provided electronically but has not been provided yet. 11. Any versions of the SSM plan that have been in place 2022-present This information was to be provided electronically but has not been provided yet. 12. Log of any citizen complaints received (2022-present) and responsive action if applicable The Facility indicated that they didn't have any complaints. 13. Provide a listing of all onsite combustion sources. Not listed in the Current Title V permit. For each combustion unit onsite provide: o The make and model; This information was to be provided electronically but has not been provided yet. o The date of installation; This information was to be provided electronically but has not been provided yet. o Size or rating (MMBtu/hr, HP, kW, etc.); This information was to be provided electronically but has not been provided yet. o Fuel combusted monthly since 2020 to present (gallons, MMcf, etc.); This information was to be provided electronically but has not been provided yet. 14. Hours of operation 2021-present for all combustion engines; This information was to be provided electronically but has not been provided yet. 15. Daily Fugitive and Visible emission monitoring records 2021 to Present This information was to be provided electronically but has not been provided yet. 14 DSB ID #: ECAD-76 16. Continuous and 3-hr rolling block average Thermal Oxidizer upper chamber temperatures January 2022 to Present This information was to be provided electronically but has not been provided yet. 17. Records of calibrations for all flowmeters and thermocouples used on-site January 2022 to Present This information was to be provided electronically but has not been provided yet. V. Closing Conference Day 2 March 19, 2025 After the records review, EPA inspectors Alex Everhart, Parmatma Adhikari, Owen Ehret and Ed Owens) VA DEQ inspector (Paul Foxwell) and PWCSLF Representatives (Tammy Gumbita and Trent Magill) held a brief closing conference to ask additional questions and discuss observations. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final report do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within 60 days, with a copy to the State. Simultaneously, EPA will perform a detailed review of records and may have additional questions. The inspection concluded at 3:10 on March 19, 2025. The following have been identified as areas of concern during the inspection. They are issues that require either further investigation by EPA or additional information or explanation from the Facility. Historically the Facility has reported zero exceedance of 500 PPM methane during SEM monitoring and EPA observed 23 exceedances of 500 ppm methane during SEM monitoring on March 18, 2025. EPA flagged each location for repair at the time of observation. A table of these exceedances is included in Section II of this report. EPA informed the Facility that they should be treated as official SEM exceedances and all timelines and remedial actions as specified in 40 CFR 63.1960(c)(4) should be followed. Areas of erosion in need of repair were observed while performing SEM, photos have been included in Attachment 2. The emergency generator at the Fleet shop is not being tracked by the landfill and is not in the Facility's Title V permit. This Generator should be tracked and maintained in accordance with 40 CFR Part 63: Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and 40 CFR Part 60: Subpart IIII-- Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. 15 DSB ID #: ECAD-76 VI. List of Attachments Attachment 1: Email correspondence to Tammy Gumbita of records requested to review during inspection Attachment 2: Photo Log Attachment 3: Inspector Sign-in Sheet Attachment 4: IRWIN Calibration Log Attachment 5: SEM Log 16 From: To: Cc: Subject: Date: Attachments: Everhart, Alex tgumbita@pwcgov.org Owen, Edward; Paul.Foxwell@deq.virginia.gov; Adhikari, Parmatma; Ehret, Owen Records Request Monday, March 17, 2025 3:06:00 PM Prince William Landfill Records Request.pdf Hi Tammy, Thanks for returning my phone call. I look forward to our Clean Air Act Inspection at the Prince William County Landfill tomorrow located at 14811 Dumfries Rd, Manassas, VA 20112. We plan to be onsite tomorrow morning around 8:30. We will have our PPE (Hi-Vis Vest and Steel Toe Boots) with us. I have attached a records request of some documents we would like to review as part of the inspection. As I mentioned the most important one for tomorrow is the map of the Facility so we can plan our approach to the Surface Emissions. Feel free to reach out if you have any questions between now and when we meet tomorrow. See you tomorrow! Alex Everhart Enforcement Inspector Air Section Enforcement & Compliance Assurance Division U.S. EPA Region 3 Phone 215-814-2114 Email everhart.alex@epa.gov Prince William County Landfill EPA Clean Air Act Inspection March 2025 Records Request 1. General maps: o Map with cover types, include descriptions of the cover o Landfill cell map and year of first waste placement for each cell 2. Flares & controls o Flare monitoring data (2022-present) o Flare Performance tests (2022-present) o Collected gas flow (2022-present), (ideally 15-minute granularity, if data is saved at higher granularity that is fine too, if it is not kept at that granularity than the most granular form of that data) 3. GCCS Design Plan o Current plan & approval if applicable 4. GCCS o Map of GCCS as built o If horizontal wells are used to control areas under NSPS/NESHAP collection requirements, a description of the spacing (vertical and horizontal) and a map of the extent of the collectors o Table of wells active at any point 2022-present Drill / decommission dates as applicable (if well was installed pre-2022, drill date not needed) Well type (horizontal, vertical etc) Location of well (ideally lat/lon but otherwise identify what coordinates are used) Depth of well & depth to perforation o Wellhead monitoring and records of tuning (2022-present) Include methane, hydrogen, CO, temperature and flow rate, if available o Any wellhead HOVs approvals relevant for 2022-present, along with approvals of any alternative timelines or corrections in that time o Any monitoring of liquid depth in wells (2022-present), including identification of % of perforation obstructed Identification of wells with dewatering pumps Descriptions of any SOPs or internal guidelines that may exist relating to well dewatering 5. Annual/semi-annual reports - for 2022 to present, all: o NSPS/NESHAP/EG semi-annual reports o Air permit compliance reports o SSM reports o Annual Emission reports 6. SEM - for 2022 to present: o Include the most recent SEM reports, or at least as much of it as has been completed even if they are not a part of any final semi-annual o All recorded data GPS track of path taken Readings including non-exceedances o Records of corrective actions  Approvals of any alternatives to expansion of the GCCS or alternative timelines o Any guidance or training materials provided for the SEM technicians o Explanation for why any areas were not monitored, when applicable 7. Cover integrity - for 2022 to present: o Any records of the monthly cover integrity monitoring and associated corrective actions 8. Air permits: o All air permits active for the site in the past five years and their applications 9. Part 98 o Part 98 Greenhouse Gas Report (2022-present) o If the landfill changed the method for calculating emissions in the primary report from Equation HH-6 to Equation HH-8 in the rule (or vice versa), or is reporting using the lower estimate of the two equations, provide an explanation of the basis for that decision 10. Annual waste deposited tonnages by type from 2022 to present o Include a list of the primary sources of industrial wastes and a description for any special wastes listed o Outline of what wastes (if any) are classified as non-degradable for LandGEM maximum expected gas generation (Design Plan) along with the basis for this classification o Outline of what wastes are classified as "inert" if applicable for Part 98 reporting along with the basis for this classification 11. Any versions of the SSM plan that have been in place 2022-present 12. Log of any citizen complaints received (2022-present) and responsive action if applicable 13. Provide a listing of all onsite combustion sources.. For each combustion unit onsite provide: o The make and model; o The date of installation; o Size or rating (MMBtu/hr, HP, kW, etc.); o Fuel combusted monthly since 2022 to present (gallons, MMcf, etc.); 14. Hours of operation 2021-present for all combustion engines; 15. Daily Fugitive and Visible emission monitoring records 2022 to Present 16. Continuous and 3-hr rolling block average Thermal Oxidizer upper chamber temperatures January 2022 to Present 17. Records of calibrations for all flowmeters and thermocouples used on-site January 2022 to Present Attachment 2: PHOTO LOG Facility: PRINCE WILLIAM COUNTY SANITARY LANDFILL Location: 14811 DUMFRIES RD, MANASSAS, VA 20112 Inspection Date: 3/18/2025 - 3/19/2025 EPA Inspector(s): Alex Everhart, Parmatma Adhikari, Owen Ehret Photographer: Owen Ehret Photo Number: Photo 1 Photo Description: EW-56 with flagging marking 500 ppm exceedance at penetration Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 2 of 20 Photo Number: Photo 2 Photo Description: South Side Phase 1 Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 3 of 20 Photo Number: Photo 3 Photo Description: South of 12" Riser Erosion Close-up with Flag showing location of 500 ppm exceedance Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 4 of 20 Photo Number: Photo 4 Photo Description: South of 12" Riser Erosion with Flag showing location of 500 ppm exceedance Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 5 of 20 Photo Number: Photo 5 Photo Description: Overview RNG Facility Process Screen Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 6 of 20 Photo Number: Photo 6 Photo Description: Chilled and Product Gas Screen Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 7 of 20 Photo Number: Photo 7 Photo Description: Landfill Gas into RNG Facility Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 8 of 20 Photo Number: Photo 8 Photo Description: After Chill Flowmeter Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 9 of 20 Photo Number: Photo 9 Photo Description: Inside RNG Facility Overview Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 10 of 20 Photo Number: Photo 10 Photo Description: Air Liquide Skid Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 11 of 20 Photo Number: Photo 11 Photo Description: GC Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 12 of 20 Photo Number: Photo 12 Photo Description: Off-Spec Gas Flare Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 13 of 20 Photo Number: Photo 13 Photo Description: Tox Flare Screen Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 14 of 20 Photo Number: Photo 14 Photo Description: Tox Flare Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 15 of 20 Photo Number: Photo 15 Photo Description: Nitrogen Removal Unit (NRU) Tanks Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 16 of 20 Photo Number: Photo 16 Photo Description: PCD-03 and PCD-10 Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 17 of 20 Photo Number: Photo 17 Photo Description: Removed Generators Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 18 of 20 Photo Number: Photo 18 Photo Description: PCD-04 Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 19 of 20 Photo Number: Photo 19 Photo Description: Scale House Generator Label Prince William County Sanitary Landfill 3/18/2025 - 3/19/2025 Page 20 of 20 Facility: f ),j Date: 3f(cf2c Name Inspection Sign-In Sheet t Affiliation Title Phone Number & Email Alex Everhart EPA 7jAAT 44o ii vc b4 ___________ P,fa lV// iL JJL/ \ EQ Enforcement Inspector 215-814-2114 Everhart.AlexEPA.gov /4st)J 9'ier 73 5 f/"/ erj c WIErM 7c?- 7 -43O / ____________ S. oq- 7f -Zz W ,- /4 O'-J.p &-Q_( ____________ (5 p /dll7^ fr CO ir 77 1 ?%? e 2!6i49JH - - Facility: Date: &: /7c__ h) I ( _________________ Name Inspection Sign-In Sheet ' /( - __________________ __________________________________ Affiliation Title Phone Number & Email Alex Everhart EPA Enforcement Inspector 215-814-2114 Everhart.AlexEPA.gov __ __________________ rmcJp C:: e C /2 j 7-'- ,J SE .'(-' .Eu;r ,r.&,1j T' A'-?I . \ - L-( - 7- cA4-.k - >-v e. _______________________ 703 - 5 - f/9 gj - / 4cJ1vi?&P 4fflcb4 ' PART 1 CALIBRATION PRECISION TEST RECORD LANDFILL NAME: Prince William County Landfill DATE: 3/18/2025 TIME: 9:19 AM PM INSTRUMENT MAKE: Inficon MODEL: IRwin S/N: 92007339 CALIBRATION GAS STANDARD: 500 ppm (7) (Check cal. gas certificate (500 ppm +/-2%) MEASUREMENT #1: Meter Reading for Zero Air: Meter Reading for Calibration Gas: 0 ppm (1) 499 ppm (2) MEASUREMENT #2: Meter Reading for Zero Air: Meter Reading for Calibration Gas: 0 ppm (3) 499 ppm (4) MEASUREMENT #3: Meter Reading for Zero Air: Meter Reading for Calibration Gas: 0 ppm (5) 498 ppm (6) CALCULATE PRECISION: |(7)-(2)| + |(7)-(4)| + |(7) - (6)| 3 X 1 X 100 (7) 1 = +0.3% PERFORMED BY: Alex Everh a rt CALIBRATION GAS CERTIFICATION DATA AND EXPIRATION DATE: Zero Gas Serial Number: 304-402692062S-1pan Gas Serial Number: 304-402692063-1 Zero Gas Expiration Date: 03/16/2027 Span Gas Expiration Date: 03/16/2027 INCLUDE A COPY OF THE CALIBRATION GAS CERTIFICATION SHEET FROM GAS SUPPLIER/MANUFACTURER PART 2 RESPONSE TIME TEST RECORD LANDFILL NAME: Prince William County Landfill DATE: 3/18/2025 TIME: 9:19 AM PM INSTRUMENT MAKE: Inficon MODEL: IRwin S/N: 92007339 MEASUREMENT #1: Stabilized Reading Using Calibration Gas: 90% of the Stabilized Reading: Time to reach 90% of Stabilized Reading After Switching from Zero Air to Calibration Gas: 499 ppm 449 ppm 4 seconds (1) MEASUREMENT #2: Stabilized Reading Using Calibration Gas: 90% of the Stabilized Reading: Time to reach 90% of Stabilized Reading After Switching from Zero Air to Calibration Gas: 499 ppm 449 ppm 3 seconds (2) MEASUREMENT #3: Stabilized Reading Using Calibration Gas: 90% of the Stabilized Reading: 498 ppm 448 ppm Time to reach 90% of Stabilized Reading After Switching from Zero Air to Calibration Gas: 4 seconds (3) CALCULATE RESPONSE TIME: (1)+(2)+(3) 3 = 3.7 SECONDS (MUST BE LESS THAN 30 SECONDS) PERFORMED BY: Alex Everh a rt PART 3 STABILIZED READING AND BACKGROUND DETERMINATION LANDFILL NAME: Prince William County Landfill DATE: 3/18/2025 TIME: 9:19 AM PM INSTRUMENT MAKE: Inficon MODEL: IRwin S/N: 92007339 Stabilized Reading Determination Procedure Calibration gas standard: 500 ppm MEASUREMENT #1: Stabilized Reading Using Calibration Gas: MEASUREMENT #2: Stabilized Reading Using Calibration Gas: MEASUREMENT #3: Stabilized Reading Using Calibration Gas: 499 ppm 499 ppm 498 ppm Stable instrument reading: Measurement #1 + Measurement #2 + Measurement #3 3 Stable instrument reading: 498 ppm Background Determination Procedure 1. Upwind Reading (highest in 30 seconds): 1 2. Downwind Reading (highest in 30 seconds): 1 Calculate Background Value: Background = 1 ppm (1) + (2) 2 PERFORMED BY: Alex Everh a rt ppm (1) ppm (2) LANDFILL NAME: Prince William County Landfill Site Information DATE: 3/18/2025 Section 1 - Weather Data Weather Recorded From: On-Site Weather Station Portable Device Other If "OTHER", describe device utilized for the collection of weather information below. Phone Beginning of Monitoring Event Time: 9:19 AM Temperature: 42 F Barometer: 30.16 " Hg Humidity: 36 % Wind Speed: 7 mph Wind Direction: NW End of Monitoring Event Time: 3:54 PM Temperature: 65 F Barometer: 30.06 " Hg Humidity: 24 % Wind Speed: 4 mph Wind Direction: NW TIMESTAMP 3/18/2025 9:33 3/18/2025 10:24 3/18/2025 10:39 3/18/2025 10:42 3/18/2025 12:58 3/18/2025 13:10 3/18/2025 13:17 3/18/2025 13:22 3/18/2025 13:30 3/18/2025 14:09 3/18/2025 14:57 3/18/2025 14:59 3/18/2025 15:06 3/18/2025 15:14 3/18/2025 15:21 3/18/2025 15:25 3/18/2025 15:27 3/18/2025 15:28 3/18/2025 15:31 3/18/2025 15:33 3/18/2025 15:35 3/18/2025 15:43 3/18/2025 15:45 Location EW56 EW52 S of EW61 Manhole S lf EW61 S of 12" riser phase 2 Eastern edge of phase 2 East side of phase 2 by hcb4 Uphill from ew64 S11-2R S11-15 Isolation valve vault N11-32 NII-33 West Slope phase 2 NII-34 NII-9R HCA4 NII-25 HCA3 Near active face SII-7 NII-22 NII-11 CONCENTRATION (ppmv) 1947 964 75557 4087 690 10504 616 628 636 1692 2051 3015 3193 1217 7198 20595 3179 3228 5210 1111 4364 878 1531 LAT WGS84 38.637074 38.63702 38.637309 38.637124 38.63905 38.638718 38.638282 38.638121 38.638105 38.638058 38.641385 38.641482 38.641024 38.641051 38.640969 38.640509 38.640271 38.640263 38.640069 38.63992 38.639529 38.640372 38.640646 LON WGS84 -77.419605 -77.42171 -77.423951 -77.424001 -77.422776 -77.422487 -77.42268 -77.422908 -77.424095 -77.425699 -77.424465 -77.42465 -77.424677 -77.425228 -77.425504 -77.425489 -77.425758 -77.425756 -77.426222 -77.425919 -77.425985 -77.425055 -77.424663