Document zdrQZge1epk6e3MD789Jz3mwz

Region 2 Caribbean Environmental Protection Division Multimedia Permits and Compliance Branch CAA Inspection Report Inspection Date: 5/1/2024 Facility Name: El Coqui Landfill Facility Address: PR-923, Km 2.5, Buena Vista Ward, Humacao, PR 00741 EPA Lead Inspector: Gloria Diaz-Galarza, 787-977-5882, diaz-galarza.gloria@epa.gov EPA Asst. Inspector: Alex Rivera, 787-977-5845, rivera.alex@epa.gov Daniel Heins, 202-565-0070, heins.daniel@epa.gov Steven Rapp, 202-250-8961, rapp.steve@epa.gov Victor Tu, 212-637-3476, tu.victor@epa.gov Katherine Marmanides, 212-637-4063, marmanides.katherine@epa.gov Maria Malave, 202-564-7027, malave.maria@epa.gov Facility Contact: Gamaliel De La Mata, Landfill Operation Manager, 787-417-7063 ext. 276, gdelamata@ecwaste.com This report is a summary of observations and information gathered from the facility at the time of the inspection. The information provided does not constitute a final decision on compliance with Clean Air Act ("CAA") regulations or applicable permits, nor is it meant to be a comprehensive summary of all activities and processes conducted at the facility. Summary of Onsite Observations A. Opening Conference The representatives of the United States Environmental Protection Agency (EPA), Gloria DiazGalarza, Alex Rivera, Katherine Marmanides, Victor Tu, Maria Malave, Daniel Heins, and Steve Rapp, arrived at El Coqu Landfill Company, LLC ("ECL," or "facility") located at PR-923, Km 2.5, Buena Vista Ward in Humacao, PR at approximately 10:40 am. The EPA representatives ("the inspectors") were met upon arrival by Mr. Gamaliel De La Mata, Landfill Operation Manager. Mr. De La Mata led the inspectors to a conference room to start the opening meeting and inspection. The inspectors presented their identification credentials and provided an overview and scope of the inspection. El Coqui Landfill - PR0000007201300018 1 5/1/2024 As part of the opening conference, the inspectors asked Mr. De La Mata a variety of questions. The following is a summary of the conversation with Mr. De La Mata: 1. Landfill operations - Mr. De La Mata used the landfill drawings/layout to describe the different sections of the landfill, active and inactive areas, wells, etc. 2. Surface emissions monitoring ("SEM") - The facility has three (3) employees in charge of the operation of the facility gas collection and control system ("GCCS") and SEM, one (1) manager and two (2) technicians. At the time of the inspection, all three (3) were out of the office. The facility added that SEM activities are conducted in-house, and that the team uses an equipment similar to IRWin/SEM 5000. The facility representative mentioned that there are no areas excluded from monitoring. EPA as a follow-up asked about the coverage shown in the NSPS semi-annual reports, noting that large swaths of the vegetated north has very limited coverage in the SEM survey maps. Mr. De La Matta acknowledged that surveys in those areas may be limited to the access roads/paths and not traverse through the fully vegetated areas. He also acknowledged on follow-up that active areas were excluded for safety reasons. 3. Cover material - Mr. De La Mata informed that the type of cover material used is soil and as alternative cover the facility uses tarps, but just for the active area. The thickness of the covers are 6-8 inches for slopes and 1 foot for the deck. 4. Safety - Mr. De La Matta added that there were no dangerous areas to be aware of (health and safety considerations/concerns) that could affect the SEM inspection aside from the active area, and informed that the only challenge would be related to slippery areas due to past and current rain events. 5. Active areas - Mr. De La Mata informed that the current active areas for waste disposition, at the time of the inspection, were the area near cells 5B and 9B (towards central portion of the landfill). 6. Final cover - Mr. De La Mata stated that there was one capped area on the northwest slope of the landfill, covered with dirt, liner, and protective cover. The thickness of the covers is approximately four (4) feet in total. 7. Areas where waste has been in place fewer than 5 years - Mr. De La Mata indicated that there are areas with GCCS where the waste has been in place fewer than five (5) years and those are 9A, 9B, cell 8; cell/area 9B2 is two (2) years. 8. Type of landfill gas collection wells - There are approximately 132 wells and only two (2) horizontals in HC8 and HC9. 9. Types of waste - In terms of dedicated areas, Mr. De La Mata added that there are areas of the property dedicated to storing special wastes, such as white goods and recycling. Construction debris is managed mixed while vegetative material is managed separate. The main landfill hill does not have cells dedicated to specific waste types. 10. GCCS status - Mr. De La Mata informed that at the time of the inspection there were approximately five (5) wells disconnected from the GCCS. Also, he added that they have been disconnected for less than a month and will be back to normal in approximately a month from the day of the inspection. The facility collects around 1,700 cfm of landfill gas. 11. Vegetation on the cover / cover maintenance - According to Mr. De La Mata, the site manages vegetation on the cover by clearing areas to create trails to access the wells and conduct SEM. El Coqui Landfill - PR0000007201300018 2 5/1/2024 The inspectors explained that during the facility tour, they would capture digital images of the facility wells and any other operation using a digital point and shoot camera. The facility representatives did not express any concerns with the inspectors' capturing photos. B. Walkthrough/SEM At approximately 11:25 AM, Mr. De La Mata led the inspectors on a tour of ECL. EPA inspectors used an Elkins IRwin to perform method 21 to measure surface methane concentrations and a Forward Looking Infrared (FLIR) optical gas imaging camera to document landfill gas emissions. The facility has approximately 90 wells that have dual extraction for gas and leachate. The walkthrough used access trails to perform a limited survey of the northern, vegetated portion of the landfill, primarily focusing on monitoring accessible penetrations. Limited attempts to monitor off the trail were made, but the thick vegetation prevented a more thorough monitoring. The walkthrough continued to the un-vegetated central southern portion of the landfill, including in areas where collection was offline. After returning to the office, the Inspectors and Mr. De La Mata then drove to the western side of the landfill to monitor leachate risers and other penetrations near the western edge of the facility. Inspectors sometimes walked and sometimes drove between risers/wells during this portion of the survey. During the walkthrough the inspectors observed extensive cover integrity issues, including leachate breakouts, erosion gulleys with exposed waste, exposed waste in general through the landfill, and impenetrable vegetation full of trees with woody roots. Inspectors observed an abandoned well venting landfill gas from an open-ended hose, as well as another well venting from a sample port. Inspectors documented emissions associated with rusted infrastructure and poorly sealed leachate risers. Inspectors found high methane readings associated with the wells offline, both at the penetrations and in the surrounding areas. In total, EPA inspectors marked 55 exceedances above 500 ppm, of which 6 were above the lower explosive limit for methane. The facility walkthrough was completed at 3:50 PM and the bump check was completed by the inspectors at 3:56 PM. Before completing the bump check, the inspectors asked if the facility wanted to see a bump check of the EPA equipment, but the facility staff declined. After the bump check, the inspectors proceeded to have an internal discussion prior to the closeout meeting. See Appendix A (SEM Data), Appendix B (SEM Map), Appendix C (Photo Log), Appendix D (Instrument & Calibration Data) and closing meeting discussion summary for further details about the SEM findings and observations. C. Closing Conference At approximately 4:10 PM, the group returned to the conference room for a closing conference with Mr. De La Mata. The inspectors thanked the facility representative for his time and cooperation during the inspection. As agreed during the inspection opening meeting, the inspectors discussed with Mr. De La Mata the main findings and observations during the SEM, the following is a summary of the conversation: El Coqui Landfill - PR0000007201300018 3 5/1/2024  Although the monitoring activity did not cover the entire extent of the facility SEM plan, the inspectors were able to find 55 different locations with surface concentrations of methane over 500 ppm. o This was significantly more than the facility's own surveys, which typically find 0 exceedances. The inspectors noted that while no technicians were available to be interviewed, this discrepancy indicates likely shortcomings in training. o Most exceedances were significantly above the standard, and a handful were at flammable concentrations. Inspectors noted that large areas were not being monitored at all due to the thick vegetation. o Inspectors highlighted that there was still the requirement to both traverse at 30meter intervals and to monitor all penetrations and areas with visual indicators of elevated gas. o With cover as thin as 6 inches, tree roots penetrate the cover and create paths for gas to escape, and a full SEM survey should be monitoring all cover penetrations. o The limited surveys in the vegetated areas give a misleading impression of the emissions situation - EPA found that the paths with compacted cover typically had low emissions, but background levels increased, and exceedances were observed when venturing off the trails into the thicker vegetation, particularly at trees. o Thick vegetation was extensive across the northern half and western slope of the landfill. In addition to the unmanaged vegetation, there were extensive cover integrity issues in the bare dirt cover areas. o There was extensive exposed waste, including in areas where it was clearly not associated with recent rains. o Erosion rills were widespread. o Mr. De La Mata noted that the rainy season makes it hard to make timely corrective actions. o Inspectors noted that other landfills in high rain areas take more pro-active steps to reduce/prevent erosion from stormwater, including use of tarps, seeding, thicker cover, and conveyances to control and direct stormwater. Lack of collection near the active area was found. o This area was still subject to gas collection requirements (with at least some of the waste having been in place for five years or more). o Instead of re-routing headers, installing horizontal collectors, or other potential options, the facility opted to fully disconnect the area from gas collection. o This resulted extremely high SEM readings at the wellheads and exceedances/generally elevated readings throughout the area. Inspectors observed significant emissions via the FLIR camera and Method 21 at the leachate risers, which also had visual signs of poor maintenance. Gas was additionally observed to be venting out of a sample port on one well and out an open hose from another well. In summary, the specific areas of concern expressed by the inspectors were the following: o SEM program o Venting gas/poor maintenance on gas and leachate infrastructure El Coqui Landfill - PR0000007201300018 4 5/1/2024 o Lack of gas collection coverage/offline wells o Cover integrity o Unmanaged vegetation The inspectors informed Mr. De La Mata that the SEM data along with other supplemental documentation such as maps will be shared via email as soon as possible1. The inspectors also informed Mr. De La Mata that corrective actions should be coordinated as soon as the SEM data becomes available to the facility, and that SEM corrections should be documented and incorporated into their semi-annual reporting. Additionally, the inspectors mentioned to Mr. De La Mata that in November 2021 a site inspection was conducted with the purpose of discussing ECL's request for higher operating values (HOVs) for the operation of several gas extraction wells. During the November 2021 inspection, ECL agreed on providing EPA updated data, including carbon monoxide (CO) data for each of the wells in need of HOVs, but such submission remains pending. Mr. De La Mata requested the inspectors to share a copy of the inspection report and agreed on following up with the pending matter2. The inspectors also informed Mr. De La Mata that an inspection report will be prepared by EPA and shared within approximately 45-60 days. The inspectors concluded the inspection and departed from the facility at approximately 4:35 PM. Appendices Appendix A - SEM Data Appendix B - SEM Map Appendix C - Photo Log Appendix D - Instrument & Calibration Data End of Report Lead Inspector's Name: Gloria Diaz-Galarza GLORIA DIAZ- Digitally signed by GLORIA DIAZ-GALARZA GALARZA Date: 2024.06.05 12:19:34 -04'00' Supervisor's Name: Nancy Rodrguez NANCY Digitally signed by NANCY RODRIGUEZ RODRIGUEZ Date: 2024.06.05 13:56:02 -04'00' 1 On May 2, 2024, EPA's Daniel Heins sent the SEM documentation to EC Waste's Gamaliel De La Mata via email. 2 On May 2, 2024, EPA's Alex Rivera shared with EC Waste's Gamaliel De La Mata EPA's November 18, 2021, inspection report and follow up communications via email. El Coqui Landfill - PR0000007201300018 5 5/1/2024 Appendix A: SEM Data Table #1: SEM Exceedances ID Description A1 Leachate pipe A2 Main valve flares A3 Second valve to flares penetration and from pipe top Time 11:27 11:35 11:36 A4 GW01 11:40 A5 GW38 11:43 A6 Vegetation with leak 11:46 A7 GW05 12:00 A8 Trees off side of access path 12:13 A9 Vent on GW141 (just top) 12:19 A10 GW138 - venting disconnected 12:26 pipe, also base A11 GW130 12:33 A12 Exposed waste / distressed vegetation 12:40 A13 Exposed waste / disconnected 12:43 well A14 Disconnected well with exposed 12:45 waste A15 Disconnected well with exposed 12:48 waste A16 Disconnected well with exposed 12:50 waste A17 Exposed waste 12:51 A18 Disconnected well 12:53 A19 Exposed waste 12:59 A20 Active well (unlabeled) on top 13:01 deck A21 Active well (unlabeled) on top 13:03 deck, also seal gap A22 Active well (unlabeled) on top 13:05 deck A23 Active well (unlabeled) on top 13:09 deck A24 GW159 13:12 A25 Exposed waste (multiple hits in 13:19 area) A26 Well on top of landfill 13:20 Reading (ppm) 4744 10028 60000 at pipe top; 3280 at base 1303 2776 3523 2026 681 594 (top) 100000 at top; 3085 at base 8198 2938 Latitude 18.128724 18.129244 18.129260 18.129511 18.129316 18.129471 18.130127 18.131364 18.130634 18.130308 18.129571 18.129012 67042 18.128461 15149 18.128475 44743 18.128101 82877 18.127622 1454 1237 2919 17580 18.127448 18.127402 18.127140 18.127400 26602 18.127645 12344 18.128042 22746 18.127460 217025 998 18.127001 18.127052 12276 18.126808 Longitude -65.806713 -65.805808 -65.805951 -65.806011 -65.806492 -65.806280 -65.805912 -65.808453 -65.808182 -65.809113 -65.809979 -65.810448 -65.810520 -65.810971 -65.811226 -65.811357 -65.811606 -65.811843 -65.811419 -65.810999 -65.810514 -65.810341 -65.810006 -65.810374 -65.810770 -65.810947 A27 Erosion rill 13:22 A28 GW57 13:25 A29 Erosion rill 13:28 A30 Erosion/exposed waste 13:30 A31 Exposed waste by well 65 13:34 A32 Erosion rill 13:36 A33 Erosion rill 13:38 A34 GW161 13:40 A35 Erosion rill 13:44 A36 GW77 + area 13:46 A37 Rill on slope + surrounding area 13:49 A38 Rill at top of slop near well 13:51 A39 Rills on slope 13:53 A40 GW71 13:55 A41 Rill on slope + surrounding area 13:58 A42 GW73 14:06 A43 GW75 14:09 A44 GW74 14:12 A45 Leachate riser 5B (seal and 14:19 penetration) A46 Leachate pipe and marking pipe 14:20 nearby A47 Leachate manhole and collection penetration 14:26 A48 Well phase/cell 8 15:02 A49 GW90 15:06 A50 Leachate riser / seal 15:15 A51 Soil near leachate pipe 15:19 A52 Top of fitting, sample port, and 15:24 at base A53 GW96R - both base and bad seal 15:29 on pump A54 Leachate riser / pipe 15:33 A55 Ground by leachate riser R-6A 15:40 1810 5072 2016 3791 658 1204 744 3303 4614 46654 795 3760 2978 3747 6495 18705 909 567 13251 18.126501 18.126334 18.126400 18.126456 18.126348 18.126671 18.126805 18.126853 18.127322 18.127480 18.127886 18.128061 18.128245 18.128646 18.129096 18.128073 18.127375 18.127612 18.127172 1875 at leachate pipe; 700 at marker pipe 3873 at manhole; 800 at penetration 14498 2761 2021 1029 257924 at port; 528 at base 5725 at bad seal; 3100 at penetration 14387 16616 18.127165 18.126601 18.126829 18.127128 18.127276 18.128134 18.129080 18.129118 18.129916 18.130532 -65.811069 -65.810953 -65.810786 -65.810518 -65.810262 -65.810268 -65.809914 -65.809518 -65.809430 -65.809242 -65.809375 -65.809512 -65.809373 -65.809104 -65.808865 -65.808442 -65.808495 -65.808306 -65.807935 -65.808007 -65.807787 -65.814065 -65.813403 -65.813832 -65.813329 -65.812904 -65.812630 -65.812429 -65.811962 Probe tip was fixed on a hiking pole 8 cm from the base of the pole, all readings taken from 8 to 10 cm from the ground with the exception of the secondary readings as noted in the table and at A9, which was only observed above 500 ppm at pipe top. Background readings: Upwind: 0 ppm Downwind: 0 ppm 55 exceedances total: 500 - 1,000 ppm: 8 1,000 - 5,000: 23 5,000 - 10,000: 4 10,000 - 50,000: 14 50,000 - 100,000: 3 >100,000: 3 Appendix B: Map Red lines trace monitoring path. Exceedances are plotted and labeled as described in Appendix B. Path on western perimeter includes some stretches in vehicle driving between risers/wells. Coverage on the northern vegetated areas was primarily limited to access road/paths due to thick vegetation. The survey covered less than 40 acres of the landfill. Appendix C: Photo Log El Coqui Humacao Landfill Digital Image Log: Date 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 Time 11:09:00 AM 11:26:00 AM 11:27:00 AM 11:31:00 AM 11:35:00 AM 11:36:00 AM 11:40:00 AM 11:43:00 AM 11:46:00 AM 12:00:00 PM 12:02:00 PM 12:13:00 PM 12:22:00 PM 12:22:00 PM 12:26:00 PM 12:28:00 PM 12:30:00 PM 12:33:00 PM 12:35:00 PM 12:40:00 PM 12:43:00 PM 12:45:00 PM 12:47:00 PM 12:48:00 PM 12:50:00 PM 12:51:00 PM 12:53:00 PM 12:59:00 PM 1:00:00 PM 1:01:00 PM 1:03:00 PM 1:05:00 PM 1:05:00 PM 1:09:00 PM 1:12:00 PM 1:19:00 PM 1:20:00 PM 1:22:00 PM 1:25:00 PM 1:28:00 PM 1:30:00 PM Digital image number P5010001.JPG P5010002.JPG P5010003.JPG P5010004.JPG P5010005.JPG P5010006.JPG P5010007.JPG P5010008.JPG P5010009.JPG P5010010.JPG P5010011.JPG P5010012.JPG P5010013.JPG P5010014.JPG P5010015.JPG P5010016.JPG P5010017.JPG P5010018.JPG P5010019.JPG P5010020.JPG P5010021.JPG P5010022.JPG P5010023.JPG P5010024.JPG P5010025.JPG P5010026.JPG P5010027.JPG P5010028.JPG P5010029.JPG P5010030.JPG P5010031.JPG P5010032.JPG P5010033.JPG P5010034.JPG P5010035.JPG P5010036.JPG P5010037.JPG P5010038.JPG P5010039.JPG P5010040.JPG P5010041.JPG Description Map of the El Coqui landfill Flare station Leachate pipe Tree on cover of landfill Main valve to flares Second valve to flares penetration and from pipe top EW-01 EW-38 Vegetation with leak EW-05 Tall, dense vegetation Trees off side of access path Hills in background near landfill Ocean in background near landfill EW138 - venting disconnected pipe, also base Working face Open hose at EW-138 EW-130 Working area Exposed waste / distressed vegetation Disconnected well with exposed waste Disconnected well with exposed waste Gas bubbles through water Disconnected well with exposed waste Disconnected well with exposed waste Exposed waste Disconnected well Exposed waste Disconnected well Active well (unlabeled) on top deck Active well (unlabeled) on top deck, also gap in top seal Gap in seal Active well (unlabeled) on top deck Active well (unlabeled) on top deck with exposed waste at base EW-159 Exposed waste (multiple hits in area) Well on top of landfill (unlabeled) Erosion rill EW-57 with exposed waste at base Erosion rill Erosion/exposed waste 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 5/1/2024 1:34:00 PM 1:36:00 PM 1:38:00 PM 1:40:00 PM 1:44:00 PM 1:46:00 PM 1:49:00 PM 1:51:00 PM 1:53:00 PM 1:55:00 PM 1:58:00 PM 2:06:00 PM 2:09:00 PM 2:12:00 PM 2:12:00 PM 2:19:00 PM 2:20:00 PM 2:22:00 PM 2:26:00 PM 2:28:00 PM 3:02:00 PM 3:06:00 PM 3:15:00 PM 3:19:00 PM 3:24:00 PM 3:29:00 PM 3:30:00 PM 3:33:00 PM 3:40:00 PM P5010042.JPG P5010043.JPG P5010044.JPG P5010045.JPG P5010046.JPG P5010047.JPG P5010048.JPG P5010049.JPG P5010050.JPG P5010051.JPG P5010052.JPG P5010053.JPG P5010054.JPG P5010055.JPG P5010056.JPG P5010057.JPG P5010058.JPG P5010059.JPG P5010060.JPG P5010061.JPG P5010062.JPG P5010063.JPG P5010064.JPG P5010065.JPG P5010066.JPG P5010067.JPG P5010068.JPG P5010069.JPG P5010070.JPG Exposed waste by well EW-65 Erosion rill Erosion rills EW-161 Erosion rill EW-77 + area Rill on slope Rill at top of slope near well Rills on slope EW-71 with exposed waste at base Rill on slope with exposed waste EW-73 EW-75 with exposed waste in surrounding area EW-74 Well head EW-74 Leachate riser 5B Leachate pipe Leachate pipe Leachate manhole and collection penetration Leachate collection area Well phase/cell 8 EW-90 Leachate riser 5A Soil near leachate pipe Top of fitting and sample port EW-96R and piping EW-96R and piping with corroded flange Leachate riser and pipe, pump on ground Ground by leachate riser R-6A Appendix D: Instrument & Calibration Data The survey was conducted using an Inficon IRwin device using the Elkins Earthworks software, held by EPA Region 2 with Property Tag # B38121. Daniel Heins operated the instrument. Calibration Checks Date/Time 2024-05-01 09:55 2024-05-01 16:00 Gas Concentration (ppm) 500 500 R2 IRwin Reading (ppm) 500 400 The instrument was calibrated according to Method 21 and manufacturer instructions with zero gas and 500 ppm methane. Bump checks were conducted before and after the survey. Pre-survey bump checks show successful calibration. Post-survey bump check shows downward drift, possibly resulting in false negatives (i.e., missed exceedances) and potential underestimation of the severity of measured exceedances. Response Time and Precision Check R2 IRwin Trial Calibration Gas ppm Reading (ppm) 1 500 500 2 500 500 3 500 490 Time (s) 5 5 4 The instrument was calibrated and checked for response time and precision on 4/30/24 at 10am using the 0 air and 500 ppm from the same cylinders as during the inspection. All readings are within 10% of the known calibration value. Response times are approximately 4-5 seconds, under the maximum of 30 seconds. Calibration Gas Composition Zero air <1 ppm total hydrocarbon 500 ppm methane in air Manufacturer Airgas Airgas Lot Number 304-402941563-1 304-402960982-1 Expiration Date 2/23/2028 2/2/2028 These were used for the calibration and bump checks on May 1, 2024, for the inspection and during the response time and precision checks on April 30, 2024.