Document v6EJJe820xY5o1Leko1wnbk49

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 Connections Winnebago Landfill, Rockford, IL Daniel Heins, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Waste Connections Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: Virtual Opening Conference: May 10, 2021 On Site Inspection: June 1, 2021 Closing Conference: June 1, 2021 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist 2. Vicky Mei, Environmental Engineer 3. Karina Kuc, Environmental Engineer 4. Konstantinos Loukeris, Environmental Engineer Other Attendees: 1. Lacy Ballard, District Manager - Waste Connections 2. Dominic Remmes, Region Engineer - Waste Connections 3. Matt Crockett, Region Engineer - Waste Connections 4. Ryan Daniels, Environmental Specialist - Waste Connections 5. Connor Riordan, Technician - Waste Connections (on-site inspection only) 6. Tom Hibbert, Region Engineer - Waste Connections (on-site inspection only) 7. Josh Hay, SEM Technician - Andrews Engineering (on-site inspection only) 8. John Perkey, Counsel / Director of Air Compliance - Waste Connections (remote conference only) 9. Kaare Jacobsen, Solid Waste Division - Illinois EPA (IEPA) Contact Email Address: Lacy.Ballard@wasteconnections.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 XXX; 40 C.F.R. Part 63, Subpart AAAA, Title V Permit Requirements Virtual Conference (5/10) Start Time: 14:30 Virtual Conference (5/10) End Time: 16:30 On Site (6/1) Arrival Time: 9:15 On Site (6/1) Departure Time: 16:30 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 Connections representatives. Process Description: Winnebago Landfill (the Landfill) is a municipal solid waste (MSW) landfill located in Rockford, Illinois. The Landfill is made up of four discontiguous pieces: the combined North Unit and South Expansion Units (NU, SEU), the Northern Expansion Unit (NEU), West Expansion Unit (WEU) and the East Expansion Unit (EEU). Waste received is approximately 60% MSW, 20% construction and demolition (C&D), and 20% soils, with small amounts of special wastes. Tarps, wood chips, processed landscaping waste, contaminated soils, and foundry sands are used as alternate daily cover (ADC). C&D fines are no longer used for ADC, though it historically was used at the WEU and NEU. The NU was the original landfill at the site and was closed and capped in the 2000s. It is a presubtitle D landfill with an asphalt liner. The SEU has a liner that is an overlay onto the south side Page 2 of 8 of NU and began filling in the 1990s as an expansion to the NU. Its final closure was in 2009. The two units are continuous and together have about 60 wells producing up to about 1000 cubic feet per minute (cfm) of landfill gas (LFG). The NEU received MSW from 2009 to 2015. It still receives contaminated soils and asbestos, with approximately 5 years left in its life based on current acceptance rates. The NEU receives anywhere from 0 to 6,000 tons per day of soils. Contaminated soils are profiled and analyzed to ensure they are non-hazardous. Intermediate cover can be up to 30 feet thick with the contaminated soils. Temporary geomembrane scrims were installed on the south and southwest facing slopes in 2021 and 2019, respectively. This has been to address odor concerns. So far, 24 acres have been placed under composite membrane with protective soils, though this is not a full final cap. The NEU has approximately 130 wells which collect approximately 3,000 cfm of LFG. The WEU stopped receiving waste at the end of 2020. Currently 10 acres are under composite membrane with protective soils. An additional 47 acres are being graded and prepared for being placed under membrane this year. The final cover with vegetative layer is planned for 2022. The WEU has approximately 88 vertical wells, as well as a handful of toe collectors that will be removed with closure. These all together collect up to around 3,300 cfm of LFG. The EEU began receiving waste in 2019 and does not have a gas collection and control system (GCCS) in place yet, as the waste is less than five years old and none of the EEU is at final grade. It will be 225 acres and is currently developed to approximately 90 acres. At current rates, this will be able to accept waste for another 15 years. The EEU typically receives up to 9,000 tons of waste per weekday, and around 2,000 tons on Saturdays. Leachate is not recirculated and there is no direct liquid addition. Liquid waste is received, profiled, and poured into beds with absorbents prior to being deposited. The subtitle D sections of the landfill have leachate drainage systems which pumps to tanks to then be sent to the Rock River publicly owned treatment works (POTW). No pre-treatment is done. Previous issues with arsenic exceedances were corrected by mixing the different sources of leachate before sending the leachate to the POTW. Leachate volumes are increasing significantly, with 11 to 12 million gallons collected per year currently. There are 40 wells with dewatering pumps at the NEU, with none at the WEU, NU, or SEU. Another 10 to 15 pumps are planned for the NEU. A consent order with the State of Illinois requires quarterly monitoring of depth to liquid, total liquid head, and percent of screen submerged in the gas collection wells. Three flares are used to control the collected LFG. Gas from all of the units are co-mingled and by default all flares are operating at all times. The system capacity is 10,500 standard cubic feet per minute (scfm), with one flare at 2,500 scfm and two at 4,000 scfm. The system is typically collecting about 8,000 scfm, and so the system does not have capacity for one of the 4,000 scfm flares to go down. Some gas from the NEU and all gas from the WEU is treated to remove sulfur. The sulfur treatment has four media bed boxes, run two at a time. When one pair of boxes see sulfur breakthrough the gas is routed to the other pair. Waste Connections changes out the media of the sulfur treatment system approximately every two weeks after both pairs of boxes Page 3 of 8 see breakthrough. When changing out the media, they stop collecting gas for 8 to 10 hours. The header vacuum at the blowers is 55 inches of water, but 25 inches are lost through the sulfur treatment system, resulting in a system vacuum of 20 to 25 inches. Staff Interview: When EPA asked if there was any policy for when to install a de-watering pump in a well, Lacy Bollard stated that there is no prescriptive guide, but decisions are made based on water level, on-site observations, surface emissions monitoring (SEM) results, and gas quality. He agreed that it was conceivable that a well with long term 100% water obstruction would not necessarily be targeted for adding a de-watering pump if its wellhead parameters were in compliance and no SEM exceedances were found nearby. De-watering pumps are generally considered a last resort due to their technical challenges. SEM, odor detection, and cover integrity observations are used to determine whether a well is collecting all of the gas being generated near it. The NEU has approximately 50 more wells than in the original GCCS design plan. The density of wells was originally increased so that the radius of influence and pull could be reduced to decrease air infiltration for a potential renewable natural gas (RNG) plant. Potential RNG plans have adjusted to have more flexibility with gas quality so all of the wells are being operated now with full vacuum to reduce concerns of fugitive emissions. When EPA asked why the GCCS is shut down for when they change the carbon beds used for sulfur removal, Waste Connections stated that they cannot change the carbon media for one pair of beds while the other is running because of leaking gas creating a hydrogen sulfide exposure risk. They stated that the sulfur rich gas eats away at the valve seals resulting in leakage. Waste Connections plans on installing a new sulfur treatment system by fall 2021, which will eliminate the shutdowns at changeouts. The new system should increase GCCS system vacuum to 50 inches. Waste Connections is looking into starting a renewable natural gas facility at Winnebago, but this is not a solidified plan at this time. Waste Connections contracts the SEM to Andrews Engineering. SEM is conducted in an enhanced program pursuant to a state consent order. The WEU and NEU are monitored monthly, while the NU/SEU is monitored quarterly. The exceedance threshold per the order is 300 parts per million (ppm), stricter than the New Source Performance Standard threshold of 500 ppm. The SEM plan requires monitoring at a grid of points as well as penetrations and at any visual indicators of potential leakage, and has an additional requirement for keeping average methane concentration below a threshold of 50 ppm averaged over grid cells designated on the landfill surface. Lacy Ballard and Josh Hay stated that historically, technicians only recorded the approximate average reading at each point, instead of recording the maximum reading observed as per Method 21. There is one gas boundary probe on the NU, close to the boundary with the SEU on their east side, that has had problems with gas migration hits. Two other locations have been addressed with slat collectors. Waste Connections stated that they have no action plan yet for this probe. Page 4 of 8 The Landfill has historically received a large number of complaints, typically in waves. Lately there has been a lull in complaints. When Waste Connections receives a complaint, they check the location and wind direction. The EEU will have an entirely separate GCCS, not co-mingled with the existing flares. NSPS gas collection requirements are not yet effective for the EEU because none of the unit is at final grade and all waste there is less than 5 years old. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA and IEPA conducted a partial SEM survey of the facility, with Josh Hay, a technician from Andrews Engineering confirming readings. The NEU was surveyed in the morning, and the WEU was surveyed in the afternoon. Exceedances of above 300 and 500 ppm total hydrocarbon (THC) as methane were recorded. Confirmation measurements were taken when a second instrument was available. Thirty-two SEM hits above 300 ppm were found on the NEU, of which 24 were above 500 ppm. Thirty-six hits above 300 ppm were found on the WEU, of which 35 were above 500 ppm. Hits were found both at penetrations and mid-landfill. The full SEM data and map of hits can be found in Appendix B. WEU well #8 had a hole in the PVC header. Large portions of both the WEU and NEU were bare soil. EPA observed erosional features and leachate breakouts. Some areas of the landfill appeared to have persistently elevated methane concentrations above 100 ppm, though EPA did not evaluate if these areas were above the 50 ppm grid-average threshold from the consent order. The instrument Josh Hay used had a length of PVC pipe affixed surrounding the probe tip. Mr. Hay stated that it was sized so when the end of the pipe was placed flush on the ground that the probe tip would be 10 centimeters from the ground. He stated that when taking a measurement at a point, he would place the probe straight down on the landfill surface and wait for two times the response time to get a reading. When asked about monitoring in areas where the temporary geomembrane scrim sat above the surface of the landfill, he said that he would try to push it down to the soil to take the reading. EPA found that this was not possible at many penetrations, as the scrim was pulled upward at the base of the wells. As a result, neither EPA nor Josh Hay were able to monitor fully around the base of many wellheads under the temporary scrims. Clouds of dust were seen coming off of the NEU. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. Page 5 of 8 RECORDS REVIEW Requested and reviewed prior to inspection: Cover integrity reports, from May 2020 to present PDF of the most current depiction/map of the GCCS system Map depiction of where the current working active face is located and the extent of final/intermediate cover Current GCCS Design Plan NSPS SEM reports (including any follow-up monitoring) from Q2 2020 to present with all associated recorded data Most recent depth to water measurements for each well with percent of perforation available and date of measurement, in a spreadsheet format Wellhead parameters monitoring (in spreadsheet format), including records for correction of any exceedances, from May 2020 to present Control device parameter monitoring (e.g. temperature and LFG flow to flare) in a spreadsheet format, from May 2020 to present List of any wells installed from May 2020 to present with reason for installation Waste accepted by category over the past 12 months, in a spreadsheet format if available Any performance tests for any control devices on site conducted from May 2020 to present, including but not limited to flares and any gas-to-energy engines/turbines Any gas sampling test reports (such as for HAP or for sulfur) from May 2020 to present All submitted semi-annual reports from May 2020 to present Any other records of emissions monitoring conducted over the past 12 months not included in the above Submitted applications for all active air permits A log of all citizen complaints and corresponding followup actions from May 2020 to present CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Waste Connections stated that it would be interested in performing SEM monitoring via drone to reduce burden on technicians, however this would only be if it could fully replace the on-theground monitoring for compliance purposes. They additionally indicated that when they have a renewable natural gas plant that they would potentially be open to using well auto-tuning to maximize gas collection. Requested documents: Leachate system map Copy of third party report evaluating GCCS Written operating procedures (plus correction procedures), if any, on: Cover integrity; De-watering, re-drills; Pump maintenance report from 2020 Gas and leachate flow rates by units (from the past 3 years) Page 6 of 8  SSM logs (from the past 3 years) Media swap out logs (from the past 3 years) Odor Plan with use of scentometer/H2S measurements Documentation of repair/re-monitoring of exceedances found Compliance Assistance: EPA gave input on how to properly conduct Method 21. Concerns: EPA found a high rate of SEM hits, distinctly above historic rates. Some hits were at locations that were supposed to have been recently corrected. EPA was also concerned that their sulfur treatment system requires such large gas collection downtime on a regular basis. DIGITAL SIGNATURES DANIEL Digitally signed by DANIEL HEINS HEINS Date: 2021.08.02 16:56:53 -05'00' _________________________________ Daniel Heins, Report Author Frank, Digitally signed by Frank, Nathan N_a__th_a_n________D22a_:t3e_8: :21_052_-10_.50'8_0.00_'2______________ Nathan Frank, Section Chief (IL/IN) Page 7 of 8 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 8 of 8 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Daniel Heins 2. Archival Record Location: ERC Enf_WinnebagoLandfill_IL_21 Image Number 1 2 3 4 5 File Name IMG_0313.JPG IMG_0314.JPG IMG_0315.JPG IMG_0316.JPG IMG_0317.JPG Date/Time (Eastern) 2021-06-01 11:09 2021-06-01 14:56 2021-06-01 14:56 2021-06-01 15:08 2021-06-01 15:44 Description of Image NEU Well 101, with leachate leak Dust clouds on NEU, as viewed from top of WEU Dust clouds on NEU, as viewed from top of WEU Leachate breakout near Well 87 (WEU) WEU Well 8, with hole in pipe. Appendices Page 1 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 APPENDIX B: FIELD MEASUREMENT DATA North Expansion Unit Hits Well Number or Map Label A B C D F Latitude 42.161223 42.161662 42.161754 42.162186 42.16226 Longitude -89.05788 -89.057726 -89.057755 -89.05799 -89.057761 Reading 1 Value (ppm) 788 820 450 750 2620 105 42.163882 -89.062575 500 H (Leachate 42.161623 -89.06337 500 Riser) I (NEU 42.159925 -89.061337 3000 Header) 4 42.160004 -89.060532 600 J (South 42.160046 -89.060286 1500 slope header valve) K 42.162379 -89.058211 350 L 45 36 M 29 N O L404 5 9 8 115 42.164094 -89.060831 350 42.1629 -89.06432 4000 42.162513 -89.063782 1195 42.162382 -89.063477 642 42.162286 -89.063297 430 42.162324 -89.063398 750 42.162176 -89.063302 1000 42.160401 -89.061938 1400 42.159991 -89.061222 1% 42.160546 -89.060798 3% 42.160548 -89.059938 1% 42.160669 -89.05876 1% Reading 1 Inst KL KL KL KL KL KL KK Reading 2 Value (ppm) 476 520 387 >300 558 Reading 2 Inst KJ KJ KJ KJ KJ 450 JH 460 KL Other Notes Two adjacent flags KL 2000 JH KL 330 VM VM 2500 KJ VM VM 350 KL DJH 1.50% KK KL 2000 KK KL 500 KK KL 450 KK KL 1000 KK KK 670 JH DJH 3200 JH KK 1500 JH KK 10000 KL KK 4000 JH KK 2000 JH generally elevated area, 100 to 200 ppm verified by Connor. Area of erosion generally elevated area, 100 to 200 ppm Broken air line Erosion trench Appendices Page 2 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 North Expansion Unit Hits (continued) Well Latitude Longitude Number or Map Label 37 42.163023 -89.058223 21 42.161302 -89.062344 R 42.1616333 -89.0578 S 42.1616833 -89.0578 T 42.1618167 -89.05775 U 42.1621667 -89.05775 W 42.1623833 -89.057867 X 42.1623333 -89.058017 95 42.161677 -89.058784 Reading 1 Value (ppm) 2% 1200 515 315 337 336 505 1902 384 Reading 1 Inst KK DJH KJ KJ KJ KJ KJ KJ KJ Reading 2 Value (ppm) 1200 450 Reading 2 Inst JH JH Other Notes West Expansion Unit Hits Well Number or Map Label Latitude D 42.152918 C 42.153208 68 42.153189 77 42.153121 B 42.154454 2 42.154478 36 42.153822 37 42.154748 49 42.154414 A 42.154331 Longitude -89.066368 -89.06625 -89.065892 -89.073107 -89.066112 -89.066233 -89.071972 -89.069548 -89.070862 -89.0717 60 42.152764 -89.071027 23 42.152769 -89.067997 20 42.152524 -89.067284 19 42.152979 -89.067344 24 42.153215 -89.067727 84 42.15356 -89.06786 18 42.153597 -89.067555 81 42.154256 -89.067154 16 42.15451 -89.067526 Reading 1 Value (ppm) 500 360 650 13000 500 500 6000 14000 6000 8746 Reading 1 Inst KL KL KL KL KK KK KL KL KL KJ Reading 2 Value (ppm) 396 300 500 10000 315 430 1% 3% 12000 6000 Reading 2 Inst KL KK KK KK KL KL KK KK KK KL 1% KK 1000 KK 800 JH 3315 JH 1000 KK 250 JH 1800 DJH 1100 JH 2400 DJH 5800 JH 800 DJH 950 JH 5% DJH 2500 JH 2% DJH 1300 JH 1.30% DJH 3717 JH Other Notes Gurgling, possible leachate problems flag from Q1 March Prior Flag Prior Flag Prior Flag Appendices Page 3 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 West Expansion Unit Hits (continued) Well Number or Map Label Latitude Longitude 35 42.154286 -89.068911 39 42.15388 -89.069742 34 42.153675 -89.069228 46 42.153918 -89.068813 27 42.153899 -89.068269 83 42.154069 -89.06785 28 42.153548 -89.068441 86 42.153377 -89.06905 40 42.153294 -89.06976 51 42.15356 -89.069993 50 42.153998 -89.070731 58 42.153705 -89.071476 E 42.1524667 -89.073817 F 42.1518333 -89.072 G 42.1518167 -89.071933 H 42.15185 -89.071817 I 42.1518667 -89.071433 Reading 1 Value (ppm) 2000 1.20% 4.20% 3% 2200 1700 4500 5% 6000 3.50% 1900 3250 503 667 1930 516 1118 Reading 1 Inst DJH DJH DJH DJH DJH DJH DJH DJH DJH JH JH JH KJ KJ KJ KJ KJ Reading 2 Value (ppm) 4525 8715 5.5% 2.8% 1750 1225 1503 2.6% 2300 Reading 2 Inst JH JH JH JH JH JH JH JH JH Other Notes Note: Some latitude/longitude readings for hits at wellheads are approximated from a georeferenced GCCS map. Non-wellhead coordinates are derived from handheld GPS units. Calibration and Instrument Information Karina Kuc (KK) used A56584 for the duration of the survey. Kosta Loukeris (KL) used SL1555 for the duration of the survey. Vicky Mei (VM) used A56575 until 11:10 AM, after which point Daniel Heins (DJH) used this instrument for the rest of the survey. Kaare Jacobsen (KJ) and Josh Hay (JH) used IEPA and Andrews Engineer equipment, respectively, for the duration of the survey. 8:30 AM average calibration reading with 500 ppm gas 4:00 PM drift check reading with 500 ppm gas A56584 491 476 SL1555 A56575 493 493 450 [Instrument ran out of hydrogen gas towards end of survey, but had all exceedances confirmed with second instrument] Appendices Page 4 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 Instrument response times were between 4 and 5 seconds. EPA calibration gases: Air, zero grade, THC < 1 ppm, expiration 05/2026 Methane 500 ppm, expiration 05/2025 The upwind and downwind readings were taken with SL1555. Upwind: 0.5 ppm Downwind: 0.7 ppm Map of Detected Hits SEM hit locations plotted over satellite imagery from April 7, 2019 as depicted on Google Earth. West Expansion Unit Appendices Page 5 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 North Expansion Unit Appendices Page 6 of 7 Facility Name: Winnebago Landfill Facility Location: 8403 Lindenwood Rd, Rockford, IL 61109 Date of Inspection: May 10 & June 1, 2021 North Expansion Unit west slope in detail Appendices Page 7 of 7