state of new hampshire air resources … · ultimately led to the nh department of justice in 2006...

STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES

AIR RESOURCES DIVISION

Onsite Full Compliance Evaluation Report

Waste Management Of New Hampshire, Inc. Turnkey Recycling & Environmental Enterprise

97 Rochester Neck Road Rochester, NH 03839

AFS # 3301700003

Inspection: September 18 through 21, 2007 Report Drafted: February 23, 2008

Report: November 3, 2008

WMNH - Turnkey Recycling & Environmental Enterprise Onsite FCE. September 18, 20 &21, 2007 Rochester

I. Inspection

On September 18, 20 and 21, 2007 the New Hampshire Department of Environmental Services, Air Resources Division ("DES") conducted an onsite full compliance evaluation ("FCE") of Waste Management of New Hampshire Inc., Turnkey Recycling & Environmental Enterprises ("TREE"), located in Rochester, Strafford County. DES' onsite FCE was conducted in accordance with EPA's Compliance Monitoring Strategy. DES and EPA Region 1 last conducted an onsite inspection of TREE in June 2004. There were a number of violations determined as a result of that inspection (See Section VIII of this report).

Date/Time of Inspection: 09/18/07, from 1000 to 1515 hours (facility tour), 09/20/07, from 0930 to 1400 hours (records review), 09/21/07, (records review).

Type of Inspection: Onsite FCE Inspected by: Michael O'Brien and Ray Walters Weather: During facility tour, clear with light winds, approx.75°F Source Contact: William Howard, District Engineer

(603) 330-2105

Last compliance inspection conducted at the facility: DES discovered a number of violations during and following the onsite inspection of TREE in June 2004. Violations of 40 CFR 60 Subpart WWW included monitoring, recordkeeping and reporting deficiencies and excess emissions. These violations ultimately led to the NH Department of Justice in 2006 issuing a Consent Decree to TREE which included a monetary penalty.

During the 2007 inspection, there were no landfill gas ("LFG") odors detected on approach to the facility. During the facility tour of the landfill and associated control devices on 9/18/07, there was no opacity observed from the staëks for the engines, flares or turbines.

On 09/18/07, the first of the 3 days necessary for this FCE of TREE, the inspectors met with Mr. Howard to discuss the purpose of the compliance inspection. He agreed to the inspection, authorized access to the facility, and provided all requested information. None of the information provided in this report was claimed to be confidential. Mr. Howard conducted an extensive tour of the facility on 09/18/07. The following 2 days of the FCE were for the review of records required to be maintained by TREE's air permits.

TREE is operated by Waste Management of New Hampshire ("WMINH") and is one of approximately 300 multi-faceted solid waste management facilities owned by its parent company, Waste Management, Inc., which is headquartered in Houston, Texas. Waste Management, Inc. operates 413 collection operations, 370 transfer stations, 283 active landfill disposal sites, 17 waste-to-energy plants, 131 recycling plants, 95 beneficial-use landfill gas projects and 6 independent power production plants. The predominant sources of air pollutant emissions at TREE are the landfills, the landfill gas

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WMNH - Turnkey Recycling & Environmental Enterprise Onsite FCE: September 18, 20 &21, 2007 Rochester

recovery systems (which include five flares, four engines, one emergency generator, and two turbines), the leachate treatment plant, fugitive dust (generated by vehicular traffic, landfill operations, construction activities, and the removal of material from on-site borrow pits for use as cover material), and spray painting operations at the maintenance facilities

II. Process Description

On June 21, 1979, TREE began operating and accepting waste in TLR I. In 1983, TREE was purchased by WMNH. TLR II was opened and began operating in June 1990. On September 22, 1992, TREE notified DES that TLR I, which is approximately 49 acres and contains approximately 2,800,000 tons of refuse, had reached its permitted final grade and it had ceased accepting refuse as of August 17, 1992. TLR I was capped in September 1992. TLR II is about 50 acres and contains approximately 3,800,000 tons of refuse. TREE closed TLR II in June 1997. TLR III is currently active and is permitted by the DES Waste Management Division to accept municipal solid waste ("MSW") until the year 2010. TREE currently employs approximately 155 people and accepts waste at the landfill on Monday through Friday from 6 a.m. to 6 p.m., and half a day on Saturday. On average, approximately 900,000 tons of trash are received and processed annually at the Facility.

All three landfills are equipped with an active LFG recovery system that distributes LFG to a number of on-site control devices. TREE operates two landfill gas-to-electricity plants to manage and combust the gas. The LFG is generated by anaerobic decomposition of the MSW and the gas is approximately 50% methane. Four identical Caterpillar Model 3516 reciprocating engines are housed in one energy plant, each engine having a maximum generating capacity of 720 to 880 KW of electricity. The second energy plant consists of two Solar Centaur stationary LFG turbines, each with a maximum permitted LFG flow rate of 1,650 scfm @ 60°F. Each turbine has a maximum generating capacity of approximately 3,300 KW of electricity. Excess LFG is combusted in the Ultra Low emissions Flare No. 3 which has a design LFG flow rate of 3,900 scfm or in Landfill Gas Flare No. 1 or 2, both with a design LFG flow rate of 1,495 scfm. Flare No. 4 is a portable flare rated at 800 scfm.

TREE accepts a variety of waste which includes municipal solid waste, contaminated soils, ash, sludge asbestos, and other special waste. For a number of years TREE accepted construction and demolition waste ("C&D"). The C&D was used as an alternative daily cover material. However, the C&D contains wall board, i.e. gypsum, which under anaerobic landfill conditions reduces the sulfate in the gypsum to H 2S. The H2 S gas is collected as part of the LFG in the gas extraction wells and is subsequently combusted in the control devices. When the LFG is combusted, the H25 is oxidized to SO2. Gas which is not collected by the gas extraction wells escapes the landfill as fugitive emissions. On July 16, 2004, DES Waste Management Division sent WMNH a letter banning the use of C&D as cover. The ban went into effect on July 26, 2004.

IlL Observations

During the inspection, Mr. Howard provided a tour of the facility and provided all requested information, none of which was deemed confidential. No odors were smelled at the office on Taylor Street or at the TLR III landfill. TREE was also watering the dirt roads, no fugitive dust

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WMNH - Turnkey Recycling & Environmental Enterprise Onsite FCE: September 18, 20 &21, 2007 Roche ster

was observed and they were actively filling Phase 8B with solid waste.

TREE was operating both of its LFG fired turbines which receives LFG from the TLR III landfill only. At the time of the inspection, LFG flow rate to Turbine No. 1 was 1,357.9 scfm and was generating 2,928 kilowatts. Turbine No. 2 had a LFG flow rate of 1483.0 scfm and was generating 2838 kilowatts. No visible emissions were observed from either Turbine No. 1 or No. 2 outlet stack.

TREE was operating its four LFG fired engine generators at the time of the inspection. Total flow to the engine generator plant is measured by one LFG flow meter. At the time of the inspection, the total LFG flow to the engine generators was 1,142 scfm. Engine generator No. 1 was generating 760 kilowatts, Engine generator No.2 was generating 780 kilowatts, Engine generator No. 3 was generating 780 kilowatts and Engine generator No. 4 was generating 800 kilowatts. Observations were made of each of the engines exhaust stack, no visible emissions were observed.

Flare No. 1, which is an open flare, was not operating during the inspection and I was told by Mr. Howard that it is used as a backup only for when one of the other LFG control devices were down. Mr. Howard said that when it is operated, it is combusting LFG from either of the three landfills. Flare No. 2, which is an open flare, had a LFG flow rate of 867.2 scfm and an exit temperature of 842° F. No visible emissions were observed from the stack. Flare No. 3, which is the Ultra Low Emissions enclosed flare was not operating at the time of the inspection. However, when it is operated it combusts LFG from either the TLR I, II, and/or III landfills.

Flare No. 5, which is an open flare was operating with a LFG flow rate of 2,100 scfm with a stack temperature of 1,090° F. Flare No. 5 is located on the TLR III landfill and as such combusts TLR III LFG only. A visible flame was observed from the flare stack; however there were no visible emissions observed.

Flare No. 6, which is an Ultra Low Emission enclosed flare was operating with a LFG flow rate of 2,300 scfm and a stack temperature of 1,545 ° F. Flare No. 6, which is located on the far side of the TLR III landfill near the Cocheco River, receives LFG from the TLR III landfill only. No visible emissions or flames were observed from the stack at the time of the inspection.

According to Mr. Howard, approximately 4,000 to 5,000 tons per day of municipal solid waste is accepted and disposed of on the TLR III landfill. At the end of each day, cover materials, such as soils or tarps to prevent the blowing of litter.

A tour was also conducted of the recycling center; no odors were detected or fugitive dust observed in this area of the Facility. It was also noticed that the area is well maintained and organized such that individuals could unload recyclable materials in an orderly manner. At the recycling facility, approximately 110 tons per day of recycled material is accepted.

Leachate from the three landfills is treated at TREE's leachate treatment plant. Approximately 45,000 to 50,000 of leachate is treated per day. Once the leachate is treated and testing demonstrates that the water quality meets permit limits it is achieves prior to disposal to the Rochester Waste Water Treatment Facility. Small amount of leachate is re-injected back into the

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• WMNH - Turnkey Recycling & Environmental Enterprise Onsite FCE: September 18, 20 &21, 2007 Rochester

landfill and only at the active face of the TLR III landfill.

Rochester Haling is a business at the facility which occupies the maintenance building located near the TLR I and III landfills. During a tour of the maintenance building, no fugitive emissions were observed. There were odors in the building, but no odors detected outside.

IV. Regulatory Compliance

CHAPTER Env-A 500 - Standards Applicable to Certain New or Modified Facilities and Sources of Hazardous Air Pollutants

TREE is subject to the New Source Performance Standards (NSPS) of 40 CFR 60, Subpart WWW, Standards of Performance for Municipal Solid Waste Landfills, 40 CFR Part 60 Subpart GO— Standards of Performance for Stationary Gas Turbines specified in Env-A 503.01(d). It is also subject to the National Emission Standards for Hazardous Air Pollutants for Source Categories (Maximum Achievable Control Technology, or MACT, Standards) 40 CFR 63 Subpart AAAA-National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills specified in Env-A 505.01. It is not subject to any of the National Emission Standards for Hazardous Air Pollutants (NESHAP) specified in Env-A 504.01.

CHAPTER Env-A 600 - Statewide Permit System

TREE emits greater than 100 tons each of SO2, NO R , and CO per year and is considered a major source for these pollutants. It submitted an application for a Title V Operating Permit on June 28, 1996. At that time, it was only considered major for its emissions of NO R . On November 25, 1996, DES sent TREE a letter stating that the application was determined to be timely and complete; therefore, the application shield provisions of Env-A 609.07 are in effect. TREE currently has 10 individual permits to operate the 4 LFG engine generators, 2 LFG Solar turbines, the emergency generator, 3 ground flares, 2 ultra low LFG enclosed flares, and one back-up LFG flare. One ofthe permits is for facility-wide Volatile Organic Compound ("VOC") emissions. Although all permits have expired, each is still valid due to Application Shield provisions in Env-A 609; Table 1 highlights the permitted devices at this facility, the operating limits and capacities, the date each permit expired, and the LFG combusted by each device in calendar year 2006.

Table 1, TREE LFG Control Devices

Device and Permit Number Operating Limits Permit CY 2006 LFG Expiration Combusted Date

Caterpillar Model 3516 10.0 MMBtu/hr (LHV), 03/31/02 159.39 MMcf Reciprocating Engine #1, Power output of 720-8 80 PO-13-1821 KW

Caterpillar Model 3516 10.0 MMBtu/hr (LHV), 03/31/02 160.09 MMcf Power output of 720-8 80

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WIvINH - Turnkey Recycling & Environmental Enterprise Onsite FCE: September 18, 20 &21, 2007 Rochester


Reciprocating Engine #2, KW

P0-13 - 1822

Caterpillar Model 3516 10.0 MMBtu/hr (LHV), 03/31/02 160.0 MMcf Reciprocating Engine #3, Power output of 720-8 80

PO-B-1823 KW

Caterpillar Model 3516 10.0 MMBtu/hr (Lily), 03/31/02 158.74 MMcf Reciprocating Engine #4, Power output of 720-8 80

P0-13-1824 KW

Solar Centaur Turbine #1 42 MMBtu/hr (LHV), 08/31/03 753.78 MMcf

Model GSC 4500, 1,500 scfm of landfill gas

PO-B-2010

Solar Centaur Turbine #2 42 MMBtu/hr (LHV), 08/31/03 751.67 MMf

Model GSC 4500, 1,500 scfm of landfill gas

PO-B-2001

LFG-Fired Flare #1 (back-up) 49.5 MMBtu/hr (HHV), 3/31/08 73.59 MMcf

McGill Environmental, 1,500 scfm of landfill gas

TP-B-0525

LFG-Fired Flare #2 41.9 MMBTU/Hr (LHV) 3/31/02 371.8 MMcf

McGill Environmental,

PO-B- 1927

Ultra-Low Emissions LFG 128.7 MMBtu/I-Ir (HHV), 05/31/03 1,454.78 MMcf Fired Flare #3 3,900 scfm of landfill gas

John Zink Company,

TP-13 -0482

LFG-Fired Flare #4 26.4 MMBtuJhr (HHV), 3/31/08 41.97 MMcf

TP-13-0525 800 scfm of landfill gas

(Taken out of service in 3106)

Flare #5 105.6 MMBtu/hr (HHV), 3/31/08 785.27 MMcf

cialties Inc., 3,200 scfm of landfill gas LLFG-Fired

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w Emissions LFG 115.5 MMBtu/FIr (HHV), 3/31/08 286.18 MMcf

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Fired Flare #6 3,500 scfm of landfill gas

John Zink Company

TP-B-0525

Facility VOC Emission, 49.9 tons/yr VOCs 10/31/01 724.09 MMcf

PO-BP-2727

PART Env-A 604.02 - Permit Terms and Conditions TREE operates the LFG control devices 365 days per year with facility-wide emission limits. Emissions are calculated based on the amount of LFG combusted in each device. Table 2 shows the emission limits and the calculated and reported emission rates for each device and the facility for calendar year 2006.

Table 2, Calendar Year 2006 Emissions

Device NOx' CO' PM 10 S02 2 VOCs

Emission Limits: 3.5 lb/hr 7.3 lb/hr

Engine #1 1.6 lb/hr (2.4) 4 6.2 lb/hr (4.8)4 0.44 ton/yr 5.44 ton/yr 0.12 ton/yr

Engine #2 1.6.lb/hr (2.5)4 7.2.lb/hr (5,9)4 0.44 ton/yr 5.44 ton/yr 0.12 ton/yr

Engine #3 2.6 lb/hr (2.7) 4 7.3 lb/hr (5,5)4 0.44 ton/yr 5.44 ton/yr 0.12 ton/yr

Engine #4 2.3 lb/hr (2.5)4 5.8 .1 b/hr (4.6) 0.44 ton/yr 5.38 ton/yr 0.12 ton/yr

Flare #1 (tons/yr) 1.38 1.67 0.05 2.09 0.05

Emission Limits: 2.9 lb/hr 14.2 lb/hr 0.2 lb/hr 2.9 lb/hr 0.4 lb/hr

Flare#2 1.67 lb/hr 8.29 lb/hr 0.06 lb/hr 3.02 lb/hr 0.06 lb/hr

Emission Limits: 2.9 lb/hr, 6.93 lb/hr, 2.32 lb/hr, 1.66 lb/hr,

Flare #3 12.6 ton/yr 30.4 ton/yr 10.1 ton/yr 7.3 ton/yr 0.56 lb/hr(2.63)4 0.98 lb/hr(1.37) 4 11.33 lb/hr, 1.66 lb/hr, 2.43 ton/yr 4.26 ton/yr 7.20 ton/yr 49.23 0.53 ton/yr

ton/yr

Emission Limits: 1.8 lb/hr, 9.8 lb/hr, 0.1 lb/hr, 0.3 lb/hr,

Flare #4 7.9 ton/yr 42.8 ton/yr 0.5 ton/yr 1.5 ton/yr

(Taken out of 1.12 lb/hr 5.57 lb/hr 3.92 0.04 lb/hr, 2.00 lb/hr, service in 3106) 0.79 ton/yr ton/yr 0.03 ton/yr 1.41 ton/yr 0.03 ton/yr

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Device NOx' CO' PM 10 S022 VOCs

Emission Limits: 7.2 lb/hr, 39.1 lb/hr, 0.5 lb/hr, 48.6 lb/hr.

Flare #5 5.28 lb/hr 26.23 lb/hr 73.27 0.20 lb/hr, 9.66 lb/hr, 14.74 tonlyr ton/yr 0.56 ton/yr 26.98 ton/yr 0.57 ton/yr

Emission Limits: 2.9 lb/hr, 6.9 lb/hr. 2.1 lb/hr, 53.2 lb/hr,

Flare #6 0.60 lb/hr (1.7) 4 1.03 lb/hr (2.4) 4 1.76 lb/hr, 13.72 lb/hr, 0.48ton/yr 0.83 tonlyr 1.42ton/yr 11.05 tonlyr 0.21tonlyr

Combined Limit: 17.8 ton/yr,

Flares #5 & #6 15.22 ton/yr

Solar Turbines 6.5 lb/hr 6.3 lb/hr 0.62 lb/hr 3.3 lb/hr 0.4 lb/hr

Turbine #1 5.85 lb/hr (59)4 6.48 Lb/hr (3•9)4 0.63 lbs/hr 5.97 lb/hr 0;13 lb/hr

Turbine #2 5.79 lb/hr (59)4 4.46 lb/hr (3.6) 0.64 lbs/hr 6.08 lb/hr 0.13lb/br

Facility Limit 145.74 ton/yr3 <250 ton/yr <250 ton/yr 49.9 ton/yr 110.7 ton/yr 24.2 ton/yr Reported 2003 110.43 ton/yr 174.3 ton/yr 12.0 ton/yr

Notes: 1. Actual NOx and CO emissions for engines and turbines based on stack test-derived emission factors;

Actual S02 emissions based on monthly landfill gas sampling and hydrogen sulfide analysis;

Combined NOx limit and NOx emissions from the 4 LFG-fired engines, 2 LFG-fired turbines, and 6 flares; and

Most recent, actual compliance stack test result in 4/hr.

Based on the LFG usage that TREE reported to DES for 2006: • Flares #2, #3 and #4 exceeded the emission limits for S02 in 2006; • The annually-averaged lb/hour emissions of Solar Turbine #1 exceeded the lb/hour

emission limits for CO, PM 10, and S02; and • The annually-averaged lb/hour emissions of Solar Turbine #2 exceeded the lb/hour

emission limits for PM1O and S02.

At the time of this compliance evaluation, DES is drafting a Title V Operating Permit for TREE and the emissions data shown in Table 2 complies with all short and long-term limits in the draft permit.

PART Env-A 618 - Non-attainment Areas TREE is a major source, located in Strafford County, NH, and is in the Northeast Ozone

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Transport Region. TREE installed Flare #5 in March 2006 and Flare #6 in August 2006. In order to net out of New Source Review for the new emissions of NOx, TREE removed Flare 44 from service upon installation of Flare #5 and limited Flare #1 to back-up use only when another permitted control device is not operating. DES issued Temporary Permit TP-13-0525 to TREE on September 21, 2006 which capped total emissions from Flares #5 and #6 and stipulated the limited conditions under which Flare #1 can operate.

CHAPTER Env-A 900 - Owner or Operator Recordkeeping

PART Env-A 903.03 - General Recordkeeping Requirements for Combustion Devices TREE is required by its existing Temporary Permits TP-13-0482 and TB-B-0487, Condition IX.C.2 of both permits to record the sulfur content as percent sulfur by weight of landfill gas or in grains per 100 cubic feet of landfill gas. According to TREE this requirement is being fulfilled by sampling the landfill gas at the turbine plant which is LFG from TLR III only. The flares combust the LFG from TLR I and TLR II.

CHAPTER ENV-A 1200 - Stationary Source Air Pollution

PART Env-A 1204 - Stationary Sources of VOCs TREE has volatile organic compounds (VOCs) at the Facility which are subject to Env-A 1204.49. Landfill gas emissions shall be collected and combusted in the permitted control devices. Combined capture and control efficiency of VOCs shall be 81% or greater.

PART Env-A 1211 - Nitrogen Oxides TREE is a major source of NOx and therefore must comply with NOx RACT. TREE conducts compliance emissions testing on all 4 LFG-fired engines and both LFG-fired turbines every 3 years as required by Env-A 1211.06 and 1211.07. The last testing was conducted in December 2006.

Temporary Permit TP-B-0525, issued September 21, 2006, requires TREE to apply for a revision to NOx RACT Order No. ARD-01-001, originally issued to TREE by DES on August 26, 2002, in accordance with Env-A 1211.18 for Flares #5 and 46.

Temporary Permit TP-B-0525 also required TREE to conduct initial compliance testing of Flare #6 and periodic compliance testing at least once every 3 years thereafter. TREE conducted testing of Flare #6 on June 5, 2007.

CHAPTER ENV-A 1400 - Regulation Toxic Air Pollutants

PART Env-A 1402 - Applicability and Part Env-A 1404 - Permit Requirements

During the inspection, a review of TREE's air toxics evaluation was conducted. TREE continues to evaluate its emissions against the ambient air limits in Env-A 1450.

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CHAPTER Env-A 1600 - Fuel Specifications

PART Env-A 1604 - Maximum Sulfur Content Allowable in Gaseous Fuels Based on the results of the monthly landfill gas sampling, TREE is determining the sulfur contend of its landfill gas and calculating its S02 emissions from this data. Its indicating in its emissions inventory reports submitted to DES by April 151h that the Sulfur content in their diesel fuel does not exceed permit limits.

CHAPTER Env-A 2000 - Fuel Burning Devices

All fuel burning devices at this facility are subject to this subpart. There were no visible emissions coming from the facility.

PART Env-A 704.01 - Emission Based Fees As noted in the in the attached Full Compliance Evaluation Records Review, TREE has paid its emission-based fees thru 2006.

V. Compliance with Federal Requirements

40 CFR Part 60 Subpart GG— Standards of Performance for Stationary Gas Turbines TREE operates two LFG-fired turbines subject to this requirement. The turbines were successfully tested for NOx compliance in December 2006.

40 CFR Part 60 Subpart WWW— Standards of Performance for Municipal Solid Waste and 40 CFR 63 Subpart AAAA-National Emission Standards for Hazardous Air Pollutants: Municipal Solid Waste Landfills

TREE operates three MSW landfills at its Facility in Rochester which are subject to the requirements of 40 CFR Part 60 Subpart WWW (and 40 CFR 63 Subpart AAAA, which refer back to 40 CFR 60 Subpart WWW). Conditions of Subpart WWW require that TREE install and operate a gas collection system consisting of wells and horizontal collector lines, header piping and vacuum pumps which collect the LFG and direct it to a series of control devices, engines, turbines and flares. In addition, Subpart WWW requires monthly monitoring of pressure, temperature and oxygen or nitrogen content at each well head.

Subpart WWWç Section 60.753 Operational Standards for collection and control systems requires TREE to conduct surface monitoring in those areas of the landfill with MSW in place for 5 years or more if active, or 2 years or more if closed or at final grade. TLR I, II, and III are subject to these requirements and therefore TREE must conduct quarterly monitoring in accordance with a surface monitoring design plan that includes topographical maps with monitoring route. Quarterly Monitoring shall include the following

• around the perimeter of the collection area; • along a path that traverses the landfill at 30 meter intervals; • when visual observation indicate elevated concentrations of landfill gas, such

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as distressed vegetation and cracks or seeps in the cover, • border between capped and uncapped areas, and • all protrusions on the landfills and associated components.

TREE also monitor at the base of gas collection wells and other structural components protruding from the landfill surface.

§60.756(f) states that "any closed landfill that has no monitored exceedances of the operational standard in three consecutive quarterly monitoring periods may skip to annual monitoring. The TLR II landfill has not had any measurable exceedance above 500 ppm as methane since the third quarter 2005 and therefore is annually monitoring this landfill. A lot of work has gone into making sure that the LFG extraction wells are applying as much vacuum as possible maximizing gas collection. This is possible because the TLR II landfill was closed and capped with a geosynthetic final cover in October 1997. The geosynthetic cover material isolates the underlying waste from the outside environment preventing both air and moisture from entering the landfill.

TREE is making good progress to control the number of exceedances on its TLR I by applying more vacuum to the waste mass. TREE is balancing the applied vacuum on each well to maximize LFG collection while maintaining all of the NSPS requirements. The TLR I landfill was closed and capped in September 1992, but was not capped with geosynthetic cover materials, but 2 foot layer of re-compacted clay, 18 inches of granular protective soil and 6 inches of topsoil. Table 3 illustrates the results of the surface emissions monitoring on the TLR I landfill.

Table 3, TLR I Surface Emissions Monitoring Quarter No of Exceedances Repaired w/in 30 days Repaired w/in 120 days 4thQtr 06 2 2 NA 1st Qtr 07 Canceled Canceled Canceled 2'"Qtr07 0 3rdQtr07 2 2 NA

Notes: 1. Canceled due to weather conditions 2. NA no actions exceedances identified were repaired within 30 days

TREE TLR III landfill is the active landfill which began operating December 5, 1995. Across the approximately 106 acre landfill, LFG collection wells are installed so that there is approximately a 200 foot radius of influence from each of the wells. In some of the wells, TREE has experienced watering in the wells, and as such has installed dewatering pumps. These dewatering pumps are designed to pump water out of the wells so that there is more slotted pipe available to collect LFG from the surrounding waste mass. Table 4 illustrates the results of the surface emissions monitoring on the TLR III landfill

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Table 4 TLR III Surface Emissions Monitoring Quarter No. of Exceedances Repaired wlin 30 days Repaired w/in 120 days 41hQtr 06 115 63 52 1st Qtr 07 Canceled Canceled Canceled 2 Qtr 07 96 69 27 37d Qtr 07 39 39 NA

Due to weather and dangerous conditions on the landfills, WMNH requested and DES approved, postponing the first quarter 2007 surface emissions monitoring.

TREE is also required to perform monthly monitoring on each gas extraction well and monthly cover integrity monitoring. Monitoring involves measuring each well pressure, oxygen or nitrogen concentration and temperature and inspecting the cover for signs of failure. TREE has conducted the required monitoring of the wells. TREE is also operating a computer tracking system which allows them to track each wells performance. Reports are generated and reviewed by WMNH personnel.

TREE is required to conduct monthly cover integrity checks of its three landfills. Cover integrity checks are performed and documented on cover integrity forms. Areas identified during the cover integrity check are repaired and the corrective action is documented.

Compliance and Enforcement Status

On February 28, 2006, the NH Department of Justice issued a Consent Decree to TREE for violations beginning in 2002 which included excess emissions of landfill gas and violations of monitoring, recordkeeping and reporting requirements in Subpart WWW. TREE installed Flares #5 and #6 to control the excess LFG emissions and agreed to a $1.75 million civil penalty, including $1.4 million for "supplemental environmental projects", the largest of which is a proposed LFG-to-energy project at the University of New Hampshire.

Conclusion and Recommended Actions

DES did not identify any major deviations from TREE's permits during the inspection. Since the 2004 inspection, it was observed that TREE has taken action to control landfill gas by improving gas collection and additional oversight of operations.

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WMNH - Turnkey Recycling & Environmental Enterprise

Onsite FCE: September 18, 20 &21, 2007 Rochester

VIII. Attachements:

Waste Management Inc. 2006 Annual Report Facility Operating Plan Gas well monitoring results August 2006 Gas well monitoring results Table 4-1

Michael O'Brien Air Pollution Control Engineer Air Resources Division

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state of new hampshire air resources … · ultimately led to the nh department of justice in 2006...

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