chicago tribune reports: U.S. EPA Inspectors Find many Exceedences of methane limit, issues with gas collection and cover quality at Multiple Landfills in Illinois
The Sunday May 19th Chicago Tribune featured a front page, extensive article detailing flaws with federal EPA landfill air emissions regulations, including results from our recent Hidden Costs of Landfills report, which details findings from U.S. EPA Inspection Reports around the country - including several landfills in Illinois. Here’s the detailed findings:
Prairie View Landfill in Wilmington, outside of Chicago:
According to the U.S. EPA inspection Report, Prairie View Landfill is a municipal solid waste landfill that opened in 2004 and consists of approximately 58 acres under final cover, 78 acres under intermediate cover and 10 active acres. The EPA conducted an announced inspection on June 11, 2021, doing a limited surface emissions monitoring survey of the facility, and found:
43 points had surface methane concentrations in excess of 500 parts per million (ppm) - some extremely high.
Distressed vegetation and exposed waste were also observed.
Two structurally compromised wells on top of Prairie Hill landfill (U.S. EPA Inspection Report)
Leak detected and exposed waste (Well 88) (U.S. EPA Inspection Report)
Prairie Hill Landfill in Morrison, close to the Iowa border
The EPA conducted two announced inspections in June 2021. According to the Inspection Report, Prairie Hill Landfill has been subject to the EPA air emissions standards since 2006. The accepted waste stream includes 60% municipal solid waste, 30 to 40% inerts and construction and demolition (C&D) waste. Horizontal collectors are installed throughout the Landfill. Only Phase 6 East does not have horizontal collectors because the waste is under 5 years old. Some of the early collection wells in areas of waste that is less than 5 years old are not up to standards because of the shallow depth of the waste. Horizontal collectors are installed on an as-needed basis, such as to control odors or to replace decommissioned wells.
The EPA inspection revealed very troubling results:
The well technician present during the inspection relayed that the Facility’s quarterly surface emissions monitoring (SEM) has found few to no exceedances, but during Comparative surface emissions monitoring conducted by EPA, 51 SEM exceedances above 500 ppm were found. All of the hits, minus one, were confirmed by the Facility’s well technician.
Large areas of concern and with exceedances include the whole toe of the Landfill by GW-23.
The entire side of the slope south of the active area by GW-406 had elevated SEM measurements, exceedance hits, leachate seeps, and exposed waste.
The area within a 40 feet radius around GW-33 was elevated.
Exposed waste was seen throughout the Landfill in areas that have not been filled for an extended period of time. Healthy vegetation was minimal throughout the Landfill. Areas with vegetation have not been mowed.
Audible bubbling liquid was heard and seen in liquid-filled holes. Strong gas odors were detected in areas with SEM exceedances, especially in areas where excessively high levels of methane were detected. A pool of liquid was on the top of the Landfill with exposed waste at EPA GPS Waypoint #134.”
Video of audible bubbling liquid in a hole with methane measurements over 2% (the methane exceedence limit is 500 ppm - when you measure methane in percentages, that's many times higher than the 500 ppm limit).
Exceedence map from U.S. EPA Inspection Report
The landfill operator appears to be only monitoring a very limited area of the landfill: The EPA inspection report stated the concern that “the SEM path that the EMT SEM technician traverses only covers the closed areas of the Landfill and at specific points in those areas. The technician relayed to EPA that this path and the points monitored are under the instruction of the previous Environmental Manager.” The SEM path traversed includes only the portions of the Landfill that are in an “L” shape by the flare and the closed “football-field” shaped area of the Landfill. The SEM procedure includes monitoring at only specific points along the SEM path, as instructed and documented in a pre- drawn map provided to the well technician and does not consist of off-path monitoring nor penetration monitoring.”
The Inspection Report stated that “the Facility does not have documentation on the cover integrity standard operating procedure.”
Quad Cities Phase IV Landfill in Milan
The Quad Cities Phase IV Landfill is owned and operated by Millennium Waste, a subsidiary of Waste Connections. According to information provided to the EPA, “The Phase IV Landfill was originally permitted for 63 acres in 1995 but received a permit to expand north by an additional 66 acres in 2008. Waste has been placed on the entire originally permitted 63 acres and is still being placed on top of this area; none of the landfill is fully up to grade or in final closure.” Approximately half of the waste accepted is municipal solid waste, and the other half is construction and demolition waste.
According to the Inspection Report, Waste Connections will occasionally check the water level within their wells. They checked the well water levels in March 2021 and found that some wells were over 50% full of water.
The EPA conducted their announced inspection in May 2021. “Two EPA inspectors performed Method 21 surface emission monitoring for methane at the Landfill for about 2.5 hours, with three additional EPA inspectors assisting with notes and equipment. They found:
Methane values higher than 500 parts per million (ppm) were observed at approximately half of the gas wells.
EPA inspectors noted the systematic well leaks, the erosion and cover integrity issues throughout the landfill but specifically on the north slope, and the leachate breakout spots on the south slope.
Detections exceeding 500 ppm were also observed at other spots throughout the landfill, including at erosion channels on the north slope. Technicians from Golder Associates had been out on the Landfill earlier in the day and found approximately five methane hits. Wells on the southern and eastern end of the Landfill had dry bentonite placed around the penetrations. According to Mr. Remmes, the erosion on the north slope was not yet repaired due to inclement winter weather. Seeding for intermediate cover on the north slope did not seem to have been placed, and multiple elevated methane detections were identified in this area.
Leachate breakout spots were observed on the southern slope and leachate stains from previous leaks were observed on the west slope. Leachate sump L001, at the bottom of the west slope, had an audible gas leak at the seal, seemingly caused by a damaged cap.”
Winnebago Landfill in Rockford
Winnebago Landfill is a municipal solid waste (MSW) landfill located in Rockford, Illinois. The Landfill is made up of four discontiguous pieces. According to the Inspection Report, “Waste received is approximately 60% MSW, 20% construction and demolition (C&D), and 20% soils, with small amounts of special wastes.”
The EPA conducted an announced inspection in June 2021. They found:
“Thirty-two SEM hits above 300 ppm were found on the Northern Expansion Unit, of which 24 were above 500 ppm.
Thirty-six hits above 300 ppm were found on the Western Expansion Unit, of which 35 were above 500 ppm.
Quoting the report, “EPA found a high rate of SEM hits, distinctly above historic rates. Some hits were at locations that were supposed to have been recently corrected. EPA was also concerned that their sulfur treatment system requires such large gas collection downtime on a regular basis.” Hits were found both at penetrations and mid-landfill.
No standards for water in the wells: ”When EPA asked if there was any policy for when to install a de-watering pump in a well, Lacy Bollard stated that there is no prescriptive guide, but decisions are made based on water level, on-site observations, surface emissions monitoring (SEM) results, and gas quality. He agreed that it was conceivable that a well with long term 100% water obstruction would not necessarily be targeted for adding a de-watering pump if its wellhead parameters were in compliance and no SEM exceedances were found nearby. De-watering pumps are generally considered a last resort due to their technical challenges. SEM, odor detection, and cover integrity observations are used to determine whether a well is collecting all of the gas being generated near it.”
Land Comp in Ottawa
The Inspection Report states, “Land Comp is a municipal solid waste (MSW) landfill located in Ottawa, Illinois. Land Comp opened in the early 1990s. The landfill consists of 25 acres, 30 gas collection wells, and one flare. There are 8 acres under final cover. A 200 x 100-foot area is active on the northwest corner, and everything else is intermediate cover. The 30 wells are in intermediate cover. Land Comp accepts approximately 800 tons of waste per day. The makeup of waste is around 30% MSW and 70% construction and demolition.”
The EPA performed an unannounced inspection in June 2022. Two EPA inspectors performed Method 21 SEM at the landfill with one inspector assisting with notes and GPS equipment. Land Comp confirmed readings made by EPA inspectors. EPA was informed that quarterly surface emissions monitoring is performed at Land Comp by a third-party consultant, Civil and Environmental Consultants. Land Comp told EPA that it has been a few years since detecting any exceedances. Their surface emissions monitoring procedure includes deviating from the path and including penetrations. The EPA’s monitoring found:
There were a total of 23 exceedances found and documented by EPA - most of which were found in areas where no wells were present. Methane values that were higher than 500 parts per million (ppm) are considered an exceedance.
Dead vegetation area, exceedences 11 (3033 ppm) and 12 (1200 ppm) found (U.S. EPA Inspection Report)
Waste Management Countryside Landfill in Grayslake
The EPA Inspection Report states, “Countryside Landfill (the Landfill) is a municipal solid waste (MSW) landfill located in Grayslake, Illinois. The Landfill opened in 1974. The site consists of 136 acres, of which 24 acres are under final cover and an additional 20 acres will be placed under final cover this year. Waste Management expects to close the landfill in 5.5 years” “The gas collection and control system (GCCS) has an estimated 132-134 gas wells. For methane leaks found during surface emissions monitoring (SEM), bentonite is placed around wells to resolve the leak.”
The EPA conducted an announced inspection in September 2021. Two EPA inspectors performed Method 21 SEM at the Landfill with three inspectors assisting with notes and GPS equipment. EMT and Waste Management both confirmed readings made by EPA inspectors. They found:
Landfill operator monitoring may have been inadequate at gas wells: Most of the observed exceedances were at gas wells, in addition to a few at areas other than gas wells. One of the reasons could be that Waste Management told EPA that the monitoring technician would not move off SEM path unless there were visual indications of leaks.
There were a total of 33 exceedances found and documented by EPA.” “Waste Management has a third party, Environment Management Technologies (EMT), perform surface emissions monitoring at the Landfill. Waste Management told EPA that they average 2-3 hits per year during routine SEM.
Only one of the flares on site was operating.
Well 223- 1.00% methane exceedence (U.S. EPA Inspection Report)
