Document oemVywjNpQKqz6vZekGgV10zD

Region 2 Enforcement & Compliance Assurance Division Air Compliance Branch Inspection Date: Facility Name: Facility Address: ICIS-Air ID #: Facility Contact: EPA Lead Inspector: EPA Asst. Inspector: EPA Asst. Inspector: Other Inspector(s): Other Inspector(s): State Inspector(s): 8/24/2022 CAA Inspection Report Gloucester County Solid Waste Complex (GCSWC) 503 Monroeville Rd, Swedesboro, NJ 08085 NJ0000003401555412 Kimberly Faustino, GCSWC Assistant Administrator, 856-478-4858 Joseph Cardile, Environmental Engineer, ECAD-ACB, 212-637-4054 Victor Tu, Environmental Scientist, ECAD-ACB, 212-637-3476 Harish Patel, Environmental Engineer, ECAD-ACB, 212-637-4046 Supriya Rao, EPA Environmental Engineer, LSASD-MAB, 732-321-3622 Omer Sohail, EPA Environmental Engineer, LSASD -MAB, 732-321-4461 Giavanni Rizzo, NJDEP Environmental Specialist, 856-614-3622 I. Facility Background: The Gloucester County Solid Waste Complex (GCSWC), which is owned and operated by the Gloucester County Improvement Authority (GCIA), is located at 503 Monroeville Road in Swedesboro, New Jersey. The landfill began accepting waste in 1987 and currently accepts predominantly ash and non-degradable materials. In addition to the landfill, GCSWC also includes a scale and scale house, a maintenance facility, and an administration building. The waste footprint at the facility comprises approximately 141 acres with over 18 million tons of waste disposed of at the site. At present, the landfill has placed waste in a total of 15 cells. Three additional cells are permitted for filling. At current and projected filling rates, it is anticipated that the landfill filling will be completed after 2050. II. Pertinent Regulatory Requirements GCSWC is subject to the new Federal Plan Requirements for Municipal Solid Waste Landfills, 40 CFR 62 Subpart 000 (Federal Plan, Subject OOO) and the National Emission Standards for Hazardous Air Pollutants for Municipal Solid Waste Landfills (MACT, Subpart AAAA). GCSWC became subject to the Federal Plan, Subpart 000, in June 2021 and is no longer subject to NSPS Subpart WWW. III. List of Attendees Kimberly Faustino - GCSWC Assistant Administrator Eric Peterson - Vice President, SCS Engineers, Environmental Joseph Cardile - EPA Environmental Engineer Victor Tu - EPA Environmental Engineer Harish Patel - EPA Environmental Engineer Supriya Rao - EPA Environmental Engineer Omer Sohail - EPA Environmental Engineer Giavanni Rizzo - NJDEP Environmental Specialist Consultants Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 1 8/24/2022 IV. Pre-Inspection Notification On August 18, 2022, Inspector Cardile contacted Mr. George D. Strachan, Executive Director of GCIA, by telephone and subsequent email to confirm that EPA planned to conduct a Clean Air Act inspection of the GCSWC landfill on August 23-24, 2022 (weather permitting) that would focus primarily on methane leak detection and repair (LDAR) requirements applicable to the landfill. Inspector Cardile further explained that EPA was planning to conduct its own surface emission monitoring (SEM) during its inspection of the landfill using appropriate SEM equipment. Finally, Inspector Cardile requested that GCSWC, at the time of EPA's inspection, have available its staff and/or contractor who conducted SEM at the landfill and that EPA would like to observe GCSWC and/or its contractor perform routine calibration of their monitoring equipment and conduct comparative SEM alongside the EPA inspectors. On August 19, 2022, Mr. Strachan confirmed in an email sent to Inspector Cardile that representatives from his staff and SCS Engineers would be made available at the time of EPA's inspection. V. Entrance Conference On August 23, 2022, EPA Inspectors Joseph Cardile, Victor Tu, Harish Patel, Omer Sohail, and Supriya Rao ("EPA Inspectors") arrived at GCSWC's administrative offices in Swedesboro, NJ at approximately 10:00 AM. EPA Inspectors showed their credentials and were directed to the facility's administrative conference room which was located in the basement of a converted single-family residence, which also housed the facility's administrative offices. In the conference room, EPA inspectors were joined by Kimberly Faustino, GCSWC Assistant Administrator, and Eric Peterson, Vice President of SCS Engineers (SCS). Ms. Faustino further explained that Mr. Strachan, Executive Director of GCIA would not be available to participate at all in the inspection. EPA inspectors explained that the primary purpose of EPA's inspection was to conduct SEM of the landfill following Method 21 to monitor methane emissions from the landfill surface and conduct a record review of the facility's leak detection data. In addition, EPA inspector planned to also observe GCSWC staff and/or contractor conducting monitoring equipment calibration and performing comparative LDAR alongside EPA staff during SEM. EPA Inspectors also indicated they planned to use a Forward Looking Infrared (FLIR) Camera and Toxic Vapor Analyzer (TVA) during the inspection. Mr. Peterson then explained that the SCS Engineers staff that normally perform monitoring equipment calibrations and conduct routine LDAR/SEM of this landfill were not available and would not participate on this inspection. In response, the EPA inspectors explained that since neither GCSWC or its contractor, SCS, would be conducting comparative LDAR/SEM as requested by EPA, then any methane leaks identified by the EPA inspectors would be required to be repaired by GCSWS/SCS staff as if those leaks had been discovered during the routine quarterly SEM conducted by the landfill. Ms. Faustino explained how the landfill was constructed and waste deposited in various Phases (designated as Phases 1 through 7), one phase can encompass more than one landfill cell, the landfill currently consists of a total of 15 cells, approximately 70 % of the waste being deposited in the landfill is incinerator ash, the landfill's permitted height limitation is 220 feet, and Cell 15, which is the cell with the active face, has been opened and operating since the spring of 2021. The EPA Inspectors briefly asked if the issue with the cap not meeting the liner in the Phase 1 area of the landfill, which was identified during EPA's last inspection of the landfill in November 2018, had been resolved. Back then EPA discovered significant methane leaks near the toe drain in the Phase 1 area of the landfill, and GCSWC staff explained that the design/installation of the cap was done incorrectly, and essentially, the cap d id not meet the liner. Ms. Faustino explained that that issue had not yet been resolved. We next discussed how EPA recently came across an SCS request seeking EPA permission to operate at least one well on the landfill with elevated temperature. During this discussion, it came to light that SCS had submitted more than one Wellhead Higher Operating Value (HOV) request to EPA for approval and at the EPA inspectors' request, SCS agreed to consolidate all of their HOV requests into one new request to submit to EPA. Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 2 8/24/2022 VI. Summary of Observations At about 11:00 AM on August 23, 20022, the EPA inspectors along Mr. Peterson began conducting SEM on the GCSWC landfill which lasted for two days. The EPA team consisting of Inspectors Rao and Sohail performed EPA's SEM and recorded leak monitoring data on the landfill. The EPA team detected and identified many methane leaks (i.e., leaks in excess of 500 ppm) throughout the landfill including several readings that exceeded 10,000 ppm. Leaks were found at the bases of wellheads, flanges, covers, vents, and pipe protrusions from the top of the rain tarp covering the side slopes in Phases 2, 3 and 4. This tarp, which was installed for erosion control, also acts to collect landfill gas and funnel it upward to the upper edge of the tarp to be collected. There is no landfill gas collection on the side slopes where the tarp is located to control these emissions. Overall, EPA inspectors completed SEM over a portion of the landfill's surface area and surface penetrations in a relatively short two-day timeframe. EPA Inspectors discovered approximately 20 methane leak events in excess of 500 ppm out of approximately 90 points sampled on the landfill. This equates to a methane leak hit rate in excess of 20%. A comprehensive list, which includes the name, location, and the methane amount measured at each sampled point, is shown in Table 1 of this report titled "EPA Exceedance Report". VII. Closing Conference: At the closing conference, EPA inspectors explained that EPA does not provide compliance determinations on its inspections and how all CAA compliance determinations required EPA Supervisory review/approval. However, EPA inspectors discussed the number of methane leak events (i.e., methane leaks in excess of 500 ppm) they had identified and documented while conducting their own SEM. EPA inspectors also pointed out that GCSWC had reported zero methane leak events for each of the last five calendar quarters after conducting SEM of the entire landfill in each of those quarters. EPA inspectors re-stated that the leaks they had identified during SEM would need to be repaired and re-monitored as required by the regulations and the list of leaks identified by EPA would be provided to GCUA via email within the next few days. It was also agreed at the closing meeting that the required timeframe to repair these leaks would start upon GCSWC's receipt of EPA's leak results. EPA inspectors again expressed concern that the issue with the cap not meeting the liner in the Phase 1 area of the landfill had not yet been resolved especially given that GCSWC is now subject to the full gas collection control system operational, monitoring and reporting requirements contained in the Landfill NSPS. Furthermore, EPA inspectors requested additional follow-up information and documents from GCSWC that included, among other things, copies of wellhead monitoring data and records going back two years (i.e., temperature, nitrogen, and oxygen) and copies of landfill gas (LFG) flow rate data to the flare going back two years along with semi-annual gas composition and speciation data (i.e., TO15 analysis) of the LFG gas. EPA inspectors also reminded SCS that they had agreed to submit a new consolidated wellhead temperature HOV request to EPA for review/approval. Finally, the EPA inspectors thanked Ms. Faustino and Eric Peterson for their cooperation and availability during its two-day inspection of Gloucester County Landfill. This concluded the EPA inspection and the EPA inspectors left the landfill at approximately 4 pm EST on August 24, 2022. Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 3 8/24/2022 Table 1: EPA Exceedance Report: Table 1 cont'd: Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 4 8/24/2022 Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 5 8/24/2022 Table 1 cont'd: Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 6 8/24/2022 Lead Inspector's Name: Joseph Cardile 10/25/2022 X Joseph Cardile Lead Inspector Signed by: JOSEPH CARDILE Assisting Inspector's Name: Victor Tu 10/25/2022 X Victor Tu Assisting Inspector Signed by: VICTOR TU Supervisor's Name: Harish Patel 10/26/2022 X Harish Patel Supervisor Signed by: Environmental Protection Agency Gloucester County Solid Waste Complex (GCSWC) - NJ0000003401555412 7 8/24/2022