Document xjY24j4KebgNELK7dGrkYXZY1

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 NOV 2 1 2019 CLEAN AIR ACT INSPECTION REPORT Arbor Hills Landfill, Northville, Michigan Kenneth Ruffatto, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Arbor Hills Landfill Facility Location: 10690 Six Mile Road, Northville. Michigan Date of Inspection: October 22-24, 2019 EPA Inspector(s): 1. Kenneth Ruffatto, Environmental Engineer, Region 5 2. Vicky Mei, Environmental Engineer, Region 5 Other Attendees 1. Susan Thorneloe, Environmental Engineer, EPA Office of Research and Development 2. Scott Hamilton, Environmental Scientist, EPA Region 5 3. Justin Coughlin, Enviromnental Scientist, EPA Region 5 4. Mike Kovalchick, Senior Environmental Engineer, Michigan EGLE 5. Diane Kavanangh-Vetort, Senior Environmental Quality Analyst, Michigan EGLE 6. Scott Miller, Supervisor/District Coordinator, Michigan EGLE 7. Brian Sanders, General Manager, Advanced Disposal Services (ADS) 8. Anthony Testa, Site Landfill Engineer, ADS 9. Todd Whittle, East Region Landfill Manager, ADS 10. Randy Frank, Lead Region Landfill Gas Manager, ADS 11. Arthur Mohr, Jr., Founder/CEO, Sniffer Robotics 12. Robert Dentzman, Co-Founder/CFO, Sniffer Robotics 13. David Barron, Co-Founder/CTO, Sniffer Robotics 14. Kyle Soule, Chief Pilot & Test Flight Engineer, Sniffer Robotics 15. Chris Shilling, Sniffer Robotics Contact Email Address: Brian Sanders- Brian.Sanders(al,advanceddisposal.com; Anthony Testa- Anthonv.Testa(ci).advanceddisposal .com Purpose of Inspection: CAA Inspection & Technology Assessment Facility Type: Municipal Solid Waste (MSW) Landfill Regulations Central to Inspection: NSPS Subpart WWW, NESHAP Subpart AAAA Arrival Time: 10/22/2019 10:30AM Departure Time: 10/24/2019 1:00PM Inspection Type: D Unannounced Inspection IZl Announced Inspection OPENING CONFERENCE IZl Credentials Presented IZl CBI warning to facility provided The following infonnation was obtained verbally from ADS staff unless otherwise noted. Process Description: The Arbor Hills Landfill (the Landfill) is an MSW landfill in Northville, Michigan. Waste is currently being disposed of at the top of the Landfill and is on average composed of 100-900 tons of construction and demolition (C&D) waste and 4,000-5,000 tons of MSW. The rest of the received waste is composed of contaminated soils. The Landfill took in over 9,000 tons of waste on October 21, 2019, made up of approximately 3,500 tons of MSW, 644 tons of C&D, 4,700 tons of contaminated soil, and 81 tons of special waste. ADS estimates that the Landfill takes in approximately 2-2.3 million tons of waste per year on average, but during this year, it has taken almost 3 million tons. Numerous air lines have been installed to assist in well dewatering. There has been a noticeable increase in liquid removal from the Landfill-last year, ADS removed, on average, approximately 60,000-70,000 gallons of liquid per day and is now removing up to I 00,000 gallons of liquid per day. The Landfill has over 400 landfill gas extraction wells. Thirteen more gas wells are expected to be installed this year. Arbor Hills Energy (AHE) is currently contracted to monitor and tune the wel!field. Caisson wells are used in areas near the active portions of the Landfill. Gas is routed from the wells to a landfill gas-to-energy plant (the Plant), operated by AHE, with four gas turbines and backup flares which include two enclosed flares and an open flare. The Plant has a capacity of 9,500 standard cubic feet per minute (scfm). There is also a 500-kW generator to run Page 2 of 4 the plant if DTE power goes down. The two enclosed t1ares were recently refurbished by John Zink which included new pilots, burner tips, new floor, thermocouples, and other repairs. The two enclosed flares can operate up to 3,700 scfm and 2,360 scfm and the candlestick up to 5,000 scfm. An automated system is used to start the flares when there is a drop in vacuum pressure so to maintain 80" vacuum. There are individual blowers for each flare rated at 4,000 scfm per blower and a startup/low flow blower rated at 2,000 scfm. Staff Interview: One purpose of EPA's inspection was to observe the use of a new technology developed by Sniffer Robotics to perform surface emission monitoring. The technology utilizes a drone with an analyzer to monitor for methane concentrations along the surface of the Landfill. The technology was developed to comply with NSPS Subpart WWW and EPA Method 21. EPA observed the drone perform monitoring over a location just above a haul road on the west side of the Landfill. EPA performed monitoring (see Appendix C) over the same portion of the Landfill. This portion of the Landfill was chosen based on recent surface emission monitoring that showed elevated methane in the area. The Landfill was already aware of elevated methane around this portion of the Landfill and have been working to remedy it. TOUR.INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA toured the Landfill and was escorted around the boundary, the active area, and the composting area. EPA detected an odor in the blower building near the Plant, but this odor did not reach past the Plant area. Photos and/or Videos: were taken during the inspection. Photos and videos were taken and documented in Appendix A and B. Field Measurements: were taken during this inspection. Field measurements, as described in Appendix C, were taken using a TVA2020 at the Landfill surface. CLOSING CONFERENCE Compliance Assistance: During surface emission monitoring (SEM), EPA identified six areas of elevated methane above the 500 ppm standard. As a result, ADS is performing the corrective actions and re-tests required under the Landfills NSPS. Follow-up of actions taken to address these locations will be included in the 4th quarter SEM report. SIGNATURES Section Chief: Page 3 of 4 Facility Name: Arbor Hills Landfill Facility Location: 10690 Six Mile Road, Northville, Michigan Date of Inspection: October 22-24, 2019 APPENDICES AND ATTACHMENTS /. ApPendix A: Digital Image Log 2. Appendix B: Digital Video Log 3. Appendix C: Surface Monitoring Results (Methane) Page 4 of 4 Facility Name: Arbor Hills Landfill Facility Location: 10690 Six Mile Road, Northville, Michigan Date of Inspection: October 22-24, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: VickvMei 3. Company/Facility Name: Arbor Hills Landfill 5. Number of Images: 8 2. Date(s) of Inspection: October 22-24, 2019 4. Street Address, City, State: 10690 Six Mile Road, Northville, Michigan 6. Archival Record Location: CD-R labelled "Arbor Hills Landfill Inspection 10/22-24/2019" Image No. 1 2 3 4 5 6 7 8 File Name PA220001 PA220003 PA240007 PA240008 PA240009 PA240010 PA24001 l PA240012 Date and Time (incl. Time zone and DST) 10/22/2019 1:28 PM 10/22/2019 1:43 PM 10/24/2019 9:44 AM 10/24/2019 10:59 AM 10/24/2019 11 :05 AM 10/24/2019 11 :08 AM 10/24/201911:13 AM 10/24/2019 11:18 AM Description ofimage Flare blowers Leachate treatment Surface location 1 Surface location 2 Surface location 3 Surface location 4 Surface location 5 Surface location 6 Appendices Page 1 of 3 Facility Name: Arbor Hills Landfill Facility Location: 10690 Six Mile Road, Northville, Michigan Date oflnspection: October 22-24, 2019 APPENDIX B: DIGITAL VIDEO LOG 1. Inspector Name: Kenneth Ruffatto 3. Company/Facility Name: Arbor Hills Landfill 5. Number of Videos: 3 2. Date(s) oflnspection: October 22-24, 2019 4. Street Address, City, State: 10690 Six Mile Road, Northville, Michigan 6. Archival Record Location: CD-R labelled "Arbor Hills Landfill Inspection 10/22-24/2019" Video Number 1 2 3 File Name PA240004 PA240005 PA240006 Date and Time (incl. Time zone and DST) 10/24/2019 8:20 AM 10/24/2019 8:21 AM 10/24/2019 8:39 AM Description of Image Drone surface monitoring Drone surface monitoring Drone surface monitoring Appendices Page 2 of 3 Facility Name: Arbor Hills Landfill Facility Location: I 0690 Six Mile Road, Northville, Michigan Date of Inspection: October 22-24, 2019 APPENDIX C: SURFACE MONITORING RESULTS (METHANE) Results of EPA's surface emission monitoring at the Landfill for methane are shown below. October 24, 2019 EPA used a Thermo Scientific TVA2020 Toxic Vapor Analyzer configured as a flame ionization detector (the TVA) on October 24,2019 to measure surface methane concentrations on the Landfill. Monitoring was performed on a section of the west side of the Landfill above a haul road in accordance with EPA Method 21 and NSPS Subpart WWW. The monitoring location section was selected to compare monitoring results with the results from the drone SEM demonstration. All monitoring and calibration were done between 10:30 AM and 12:30 PM. The instrument was calibrated by Kenneth Ruffatto using a calibration gas of zero and 500 ppm of methane. The following calibration data was collected for the calibration: Trial 1 2 3 Averaoe Meter Reading ( m) 497 496 502 Difference from 500 ppm Calibration Gas ( m) 3 4 2 0 j Response Time (seconds to 90% of value) 4.3 4.3 3.3 4.0 The calibration precision is 0.6% which is within the required I 0% under Method 21. The average instrument response time is 4.0 seconds which also meets the requirement to be less than 30 seconds under Method 21. The general weather on October 24, 2019 at Arbor Hills Landfill between 10:30 AM and 12:30 PM was 52F and cloudy with no precipitation. The wind was from the NW at approximately 7-9 mph. The background concentration of methane upwind of the site was Oppm and downwind of the site was also 0 ppm with an average background of Oppm methane. Monitoring was performed by Kenneth Ruffatto. The following six areas had concentrations greater than 500 ppm. Note that only the highest concentration detected is recorded, but additional monitoring was done around these points that also showed levels greater than 500 ppm. . GPS Coord . Corresponding # Lat Long Image No. Methane (ppm) 1 42.40223 -83.56171 3 700 2 42.40142 -83.56103 4 1800 3 42.40180 -83.56108 5 523 4 42.40180 -83.56084 6 655 5 42.40205 -83.56102 7 574 6 42.40227 -83.56102 8 3608 Appendices Page 3 of 3