Advanced Disposal’s Arbor Hills Landfill in Washtenaw County has received two more violations from the Michigan Department of Environmental Quality (MDEQ). Arbor Hills Landfill has received seven MDEQ violations already this year.
A violation was issued to Advanced Disposal Services, the landfill’s owner and permit holder. Fortistar Methane Group, known locally as Arbor Hills Energy, also received a violation. Responses from these polluters are due to the MDEQ by April 4, 2019.
Landfill gas is actively collected, treated, and processed at a gas-to-energy turbine plant adjacent to the landfill. The plant is owned and operated by Fortistar Methane Group.
According to Advanced Disposal’s violation notice, “The Company is adding sewage sludge and other types of wastewater sludge material to Cell 4E… This cell is not controlled by a landfill gas collection system that has been activated, so calculations need to be done to show that the percent moisture by weight expected in the waste mass to which liquid is being added is less than 40 percent. (Note: Recent Company disclosure that as much as 27 feet of leachate was sitting on parts of the landfill liner for Cell 4 suggests the waste mass may have become saturated. This could greatly accelerate the generation of landfill gas in a location that is not yet controlled by the gas well collection system.)”
Leachate is a landfill waste product created when rainwater flows through decomposing waste and picks up toxic contaminants. The creation of leachate, sometimes called “garbage soup” or “garbage juice,” presents a major threat to the current and future quality of ground water. A release of leachate to the ground water may present several risks to human health and the environment.
The violation notice also says a leachate seep has been present at the landfill since at least May 2018 and has yet to be resolved.
The notices of violation are based on physical observations made during site inspections and records provided immediately following. The violations are significant.
According to their violation, Advanced Disposal Services is not handling asbestos properly. Warning signs are not posted, mapping of locations containing asbestos are not complete, the MDEQ’s Air Quality Division is not being notified as required prior to digging in asbestos areas. The Air Quality Division does not believe the landfill is covering asbestos daily. Uncovered asbestos can become airborne, impacting the community downwind.
According to the violation, “Based on the three (3) visits to the active asbestos disposal areas, there is a concern that the asbestos waste is not being covered with soil each evening on days after a shipment has been received. Rather, it is suspected that it is being done when a disposal pit is full which can take days or weeks. The disposal area on top of the landfill is highly exposed to wind and any asbestos from a broken bag could be quickly blown downwind. It also could represent a hazard to workers servicing nearby landfill gas wells or truck drivers in the area.”
Landfill cover is not being maintained.
Numerous problems are cited with the landfill cover the quarterly methane scans which are required to verify the landfill cover is doing its job (providing a seal on the top of the landfill). Obvious issues which are identified on inspection reports are not corrected. MDEQ does not believe the quarterly methane scans are being adequately performed. These scans should be used to identify and correct problems with the landfill cover and methane leaks.
Gas collection & control system (GCCS) non-compliant
Environmental regulations require the gas system be properly designed and maintained to handle water/liquid leachate in gas wells. Leachate levels in a significant number of the gas wells (215) cover over 50% of the perforated screen (area available for gas flow). Several wells are mostly saturated or completely blocked with leachate. The leachate is blocking the gas system from doing its job – the landfill is water-logged. The Air Quality Division presents a significant amount of data to make their point. The Air Quality Division verbally suggested the landfill will be “dewatered” in the future and they believe this will improve gas removal.
The MDEQ also points out that the landfill operators are ignoring data taken at each well in the gas system monthly. Regulations require adjustments must be made to keep wellhead pressures at a vacuum. If conditions cannot be quickly corrected, the MDEQ must be notified and Alternate Compliance Timing (ACT) must be submitted. Advanced Disposal/Fortistar are not following these required practices – this is a continuing problem which has been cited before.
Flare (Advanced Disposal)
The MDEQ states there were several incidents in which landfill gas has not been able to reach the flare for more than one hour. MDEQ verbally confirmed that the flaring capacity is still only about 5,000 standard cubic feet per minute while about 12,000 standard cubic feet per minute of landfill gas is produced at times.
The MDEQ’s Air Quality Division has requested an update on past violation notices related to Arbor Hills Landfill’s flares.
- The MDEQ noted odorous leachate seeps and the portable frac tanks which have been present since at least May 2018
- New leachate seeps, gas bubbles and an active landfill vent which is venting directly to atmosphere near six mile road were identified. Gas is being generated but is not being removed by the GCCS.
- Odorous compost is being received and stored – at a minimum, it should be quickly processed but a company concerned with odors would reject these types of loads.
- Highly odorous piles of contaminated soil are being stored, uncovered at the top of the landfill awaiting use at daily cover. The use of a cheap cover material must trump odor concerns.
- Advanced is accepting sewer sludge into cell 4. The sludge contains a high level of liquids which will accelerate gas generation. This portion of the landfill has no gas collection.
“Liquid levels for the gas wells listed in Attachment (2) raises concerns about the functionality of these gas wells. Many of the wells listed also exhibit high methane concentrations (over 55%) along with notes indicating that the valve is 100% open. This is a strong indication that liquid levels are impeding gas collection. In addition, even if the wells with high liquid levels appear to be productive currently, the long-term presence of liquids can contribute to fouling of the stone and well screen, reducing the effectiveness of these wells over time. The Company should immediately begin evaluating the gas wells listed in Attachment (2) to determine which wells warrant the installation of pumps or to identify other appropriate corrective actions.
“The site visit conducted on March 12, 2019, identified new sources of odors at the facility in addition to the TS-01 seep and associated odorous “frac” tanks. These include a new leachate seep located just west of the TS-01 seep with a leachate creek draining down towards the base of the landfill, and two highly odorous landfill gas areas coming out of the ground located above the north gee-liner. Odors were also coming from a passive landfill gas vent located near Six Mile road. In addition, there was a probable landfill gas bubble under the gee-liner on the northwest side of the landfill, a much larger gas bubble under the north gee-liner on the liner’s west side, and a surface landfill gas seep just above the TS-01 area. Please provide an update on how the Company will be dealing with these new areas of concern.