Document wqM3Rv96E9pwe7GNenVDkjL73

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 Earthmovers Landfill, LLC, Elkhart, Indiana Emma Leeds, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Earthmovers Landfill, LLC (Earthmovers) Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 EPA Inspector(s): 1. Emma Leeds, Environmental Engineer 2. Alexandra Letuchy, Environmental Engineer 3. Karina Kuc, Environmental Scientist 4. Daniel Heins, Environmental Scientist Other Attendees: 1. Chak Chakraborty - Earthmovers Site Engineer, Waste Management 2. Randy Russell - Indiana Gas Operations Manager, Waste Management 3. Clayton Franklin - Area Gas Operations Supervisor, Waste Management 4. Paul Karkiewicz - Indiana Department of Environmental Management, Environmental Manager Contact Email Address: cchakrab@wm.com Purpose of Inspection: To perform comparative Method 21 surface emissions monitoring (SEM) Facility Type: Municipal solid waste landfill Regulations Central to Inspection: 40 C.F.R. Part 60 Subpart WWW - New Source Performance Standards (NSPS) for Municipal Solid Waste Landfills; 40 C.F.R. Part 62 Subpart OOO - Federal Plan Requirements for Municipal Solid Waste Landfills; 40 C.F.R. Part 63 Subpart AAAA - National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills Arrival Time: 12:15 PM ET Departure Time: 4:30 PM ET 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 Earthmovers personnel unless otherwise noted. Process Description: Earthmovers Landfill, LLC ("the landfill") opened in 1976 with a permitted solid waste footprint of 97.8 acres and a 2:1 grade. Approximately 200 trucks drop off waste per day. Daily cover consists of 6 inches of soil provided by the City of Elkhart, and intermediate cover consists of a one-foot-thick layer of clay and seeded vegetation. The landfill is divided into 9 cells, with Cells 7 and 8b in the central area of the landfill active at the time of the inspection. Of the remaining areas, which surround the active center area, approximately half is either under final cover or pending closure certification, and the other half is under intermediate cover. The gas collection and control system consists of 107 wells, approximately 30 of which are in active portions of the landfill and will need to be redrilled. Gas is primarily routed to the on-site gas-to-energy facility at the northwest corner of the property with six Caterpillar 3516 engines. Occasionally gas is also sent to the open flare at the central northern portion of the property if the engines are out of operation. Earthmovers has a leachate collection system and an on-site wastewater treatment plant (WWTP) to treat leachate before sending it to the City of Elkhart WWTP. They currently discharge around 40,000 - 45,000 gallons of wastewater per day. Page 2 of 5 Staff Interview: EPA inspectors asked Earthmovers personnel about their SEM procedures and if they have been monitoring at penetrations, specifically wells, during SEM events. Earthmovers personnel responded the landfill has not been performing SEM at wells aside from whenever a well happens to be located along their planned serpentine path. Mr. Chakraborty stated that next quarter the landfill plans to begin monitoring at wells in accordance with the new and updated landfill regulations, which include the Federal Plan Requirements in 40 C.F.R. Part 62 Subpart OOO, and the NESHAP Subpart AAAA updates. Earthmovers also plans to start using a new instrument for SEM monitoring, the SEM5000 portable methane detector. Mr. Chakraborty explained that aside from active areas and truck paths, no areas on the landfill are exempt from SEM. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: SEM was performed on the landfill by EPA inspectors from 1:00 PM to 4:30 PM using three Thermo Scientific TVA2020 Toxic Vapor Analyzers (TVA). Inspectors split into two groups and walked on a parallel path around the full circumference of the landfill, with one EPA inspector moving between the two groups as needed to verify TVA readings as needed. Both groups were accompanied by at least one Waste Management employee. Some of the Waste Management staff would separately record any methane detections exceeding 500 ppm and verify the elevated readings, often taking photos of the readings on the TVA screen. EPA inspectors began the SEM with the intermediate cover area on the southeast half of the landfill and then moved through the final cover areas on the northwest half. Portions of the intermediate cover areas were covered in grasses several feet high, as shown in Image_9882. Portions of the landfill pending partial closure certification contained exposed waste and had not yet been seeded, shown in Image_9889 and Image_9890. A large erosion belly was observed on the west slope of the landfill containing exposed waste, shown in Image_9887, and Earthmovers personnel claimed that it would be repaired using a bulldozer within 2 to 3 weeks. Charred ground and dead insects were observed between wells GW-59 and GW-96 on the north slope in the final cover area, shown in Img_9891. Methane readings above 500 ppm were found in this charred area. Inspectors found and verified 20 locations on the surface of the landfill that exceeded 500 ppm methane. Approximately half of these exceedances were in areas with final cover or pending closure certification, and less than half of these exceedances were at wells. PVC pipes and other markers were used throughout the landfill to mark the underground gas collection and control (GCCS) systems. EPA inspectors found that several marker pipes for the underground GCCS system were penetrating the landfill cover and directly leaking methane to the atmosphere. Page 3 of 5 Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. Field measurements were taken with three TVA's and two handheld GPS devices during the SEM, and are recorded in Attachment B. RECORDS REVIEW EPA inspectors were provided with a map of the landfill portraying the active, intermediate, and closed areas, and referenced the map while performing SEM. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: The following documents were requested following the July 19, 2021 inspection to be provided via email. SEM quarterly reports (2016 - 2018), following requirements in 40 C.F.R. 60.755(c) Semi-annual reports (2016 - Jan 2019), as required by 40 C.F.R. 63.1980 Most recent technical drawing of Earthmover's surface scan route, as required by 40 C.F.R. 63.753(d) Down-time logs for engines and flare (2016 - 2021), as required by 40 C.F.R. 63.753(f)(3) Concerns: EPA inspectors noted the exceedances of 500 ppm methane found during the SEM as well as the marker pipes leaking methane as concerns. SIGNATURES Digitally signed by Emma X Emma Leeds Leeds Date: 2021.09.10 10:15:02 -05'00' Emma Leeds Report Author NATHAN X FRANK Nathan Frank Section Chief Digitally signed by NATHAN FRANK Date: 2021.09.15 14:53:58 -05'00' Page 4 of 5 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log 2. Appendix B: Field Measurement Data Page 5 of 5 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Emma Leeds (Images 1 - 11), Sasha Letuchy (Images 12 - 25) 2. Archival Record Location: https://usepa.sharepoint.com/:f:/r/sites/R5_Work/r5erc/ecad/AECA B%20Library/Enf_Earthmovers_IN_21/Enf_Earthmovers_In_21_I nsp2/Digital%20Image%20Log?csf=1&web=1&e=YbrKTv Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 File Name Image_9882 Image_9883 Image_9884 Image_9885 Image_9886 Image_9887 Image_9888 Date and Time 7/19/21, 1:56 PM ET 7/19/21, 2:21 PM ET 7/19/21, 2:28 PM ET 7/19/21, 2:37 PM ET 7/19/21, 2:47 PM ET 7/19/21, 3:03 PM ET 7/19/21, 3:12 PM ET Latitude and Longitude Image_9889 Image_9890 Image_9891 Image_9892 earthmover_169_k1 earthmover_170_k2 earthmover_171_k3 earthmover_172_173_k4 7/19/21, 3:28 PM ET 7/19/21, 4:14 PM ET 7/19/21, 4:15 PM ET 7/19/21, 4:18 PM ET 7/19/21, 1:27 PM ET 7/19/21, 1:34 PM ET 7/19/21, 1:43 PM ET 7/19/21, 1:47 PM ET earthmover_174_k5 7/19/21, 1:50 PM ET Description of Image Distressed vegetation at exceedance EL-1 Exceedance EL-2 at GW-103 Exceedance EL-3 at GW-104 Distressed vegetation at exceedance EL-5 Exceedance EL-6 at GW-94 Erosion belly created from rainstorm Exceedance EL-7, gas leaking out of top and base of PVC marker pipe Exceedance EL-9 at GW-68RR Exceedance EL-10 at GW-56 Charred ground between GW-59 and GW-96 Charred ground at exceedance EL-11 Follow-up location K1: leaking decommissioned well Exceedance K2 at GW-54 Exceedance K3 at header valve near sump 8 Exceedance K4 and multiple other elevated readings at leachate sump 8A Exceedance K5 at riser sump 8 Appendices Page 1 of 6 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 17 earthmover_175_k6 7/19/21, 1:54 PM ET 18 earthmover_176_k7 7/19/21, 2:32 PM ET 19 earthmover_177 7/19/21, 3:04 PM ET 20 earthmover_178_k9 7/19/21, 3:19 PM ET 21 earthmover_179_k10 7/19/21, 3:29 PM ET 22 earthmover_180_k11 7/19/21, 3:30 PM ET 23 earthmover_181_k12 7/19/21, 3:36 PM ET 24 earthmover_182_k13 7/19/21, 3:39 PM ET 25 earthmover_183_ 7/19/21, 3:43 PM ET Exceedance K6 at GW-53 Exceedance K7: hole near GW48 Follow-up point K8: above boot RW-1 Exceedance K9: PWA Follow-up point K10: PWB boot Exceedance K11 at marker pipe west of PWB Follow-up point K12 Exceedance K13 Follow-up point K14 Appendices Page 2 of 6 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 APPENDIX B: FIELD MEASUREMENT DATA Calibration Data and Instrument Information Emma Leeds (EL) used TVA A56584 for the duration of the survey. Daniel Heins (DH) used TVA SL1555 for the duration of the survey. Karina Kuc (KK) used TVA A56575 for the duration of the survey. Methane calibration gas expiration data Calibration Gas Lot Number Zero grade 1486172 500 ppm 304-402110297-1 1,960 ppm 304-402110299-1 10,000 ppm 304-402110298-1 Expiration Date May 2026 May 11, 2025 May 11, 2025 May 11, 2025 TVA calibration beginning at 11:45 AM, using methane calibration gas TVA Reading for 500 ppm Reading for 1,960 ppm A56575 510 2010 A56584 504 1834 SL1555 481 1890 Reading for 10,000 ppm 1.01% 9901 9750 TVA response times using 500 ppm calibration gas beginning at 11:45 AM TVA Response time (s) A56575 4.26 A56584 4.67 SL1555 4.12 Bump check with 500 ppm methane calibration gas at 5:20 PM TVA Reading A56575 478 A56584 460 SL1555 462 Background Concentrations The background concentration upwind of the site was taken near the southern border of the landfill at 41.61599, -85.97129 at 4:35 PM. The upwind reading was -2.8 ppm methane. The background concentration downwind of the site was taken on the northern border of the landfill at 41.62307, 85.97048 at 4:45 PM. The downwind reading was 0 ppm methane. Appendices Page 3 of 6 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 Surface Emissions Monitoring Data Exceedance Exceedance ID EL-1 EL-2 EL-3 EL-4 EL-5 EL-6 EL-7 EL-8 EL-9 EL-10 EL-11 K-2 K-3 K-4 K-5 K-6 K-7 K-9 K-11 K-13 measurements Latitude, Longitude 41.621333, -85.967304 41.617191, -85.970792 41.616567, -85.97072 41.616581, -85.970761 41.616664, -85.970976 41.616887, -85.971488 41.618689, -85.972964 41.618954, -85.972742 41.621694, -85.972094 41.620995, -85.969484 41.620957, -85.969416 41.618451, -85.969393 41.618306, -85.96999 41.61798,85.969788 41.617945, -85.969707 41.618191, -85.970063 41.616539, -85.971915 41.620365, -85.973695 41.620502, -85.973928 41.620763, -85.973772 from US EPA SEM survey Location Description Distressed vegetation 50 ft NW of GW-95 GW-103 GW-104 6" head riser pipe, 15 ft N of GW-104 Distressed vegetation 50 ft NW of GW-104 GW-94 6" head riser pipe, 20 ft NW of 73-RR GW-68RR 20 ft N of 13-RR GW-56 Charred ground between GW-59 and GW-96. Elevated levels also found at GW-96. GW-54 Header valve for sump 8 Leachate sump 8A and multiple sources surrounding sump 8A Clean out riser sump 8 GW-53 Hole near GW-48 PWA Pipe west of PWB Valve header Appendices Page 4 of 6 Reading 1400 Verification Reading 1100 3200 3000 1100 2200 1300 1% 1300 1000 1.80% 1.20% 2.80% 2% 700 1000 1200 2000 900 1100 1000 800 1100 800 9000 2300 2300 1100 1300 750 3500 2900 2% 2% 2000 1% 2500 5000 2000 1400 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 TVA measurements in the Reading 1 column with an "EL" Exceedance ID were taken by Emma Leeds. TVA measurements in the Reading 2 column with a "K" Exceedance ID were taken by Karina Kuc. All measurements in the "Reading 2" column were taken by Daniel Heins. Follow-up locations from US EPA SEM survey ID Latitude, Longitude Location Description EL-12 41.615996,-85.971291 GW-96 K-1 41.618574,-85.968743 Top of decommissioned well K-8 41.61969,-85.974136 Boot of RW1 K-10 41.620477,-85.973696 Boot of PWB K-12 41.620691,-85.973806 Boot of GW-180 K-14 41.620769,-85.973934 Top of marker PVC pipe Inspectors noted the above 6 locations to likely be leaking significant amounts of methane. Via email after the inspection, Earthmovers personnel confirmed that they would re-monitor at these follow-up points and correct any exceedances found as needed. Appendices Page 5 of 6 Facility Name: Earthmovers Landfill, LLC Facility Location: 26488 Country Road 26, Elkhart, Indiana 46515 Date of Inspection: July 19, 2021 Map of GPS Path, Exceedances, and Follow-up Points The red path was taken by Emma Leeds. Karina Kuc's path ran in a similar loop but further downslope and closer to the perimeter of the landfill. Unlabeled green arrows indicate locations with TVA readings that exceeded 500 ppm methane, and six additional follow-up points. Appendices Page 6 of 6