ANNUAL SITE AUDIT LANDFILL GAS CONTROL SYSTEM 2016 – … · 2019. 1. 26. · Table 31 Comparison...

November 2018 COMMERCIAL IN CONFIDENCE P0098

Registered Office: Enviraf Ltd., 16 Brook Way, Bromham, Bedford MK43 8PG, UK Registered in England and Wales, Registered No. 08708967 VAT Registered No. GB 172408124

Registered Office: Berwick Manley Associates Ltd., 71 High Street, Great Barford, Bedford MK44 3LF. UK

Registered in England and Wales, Registered No. 3124298 VAT Registered No. 650 7240 56

Enviraf Ltd/Cork City Council

Kinsale Road Landfill, Cork, Republic of Ireland

ANNUAL SITE AUDIT

LANDFILL GAS CONTROL SYSTEM

2016 – 2017

COMMERCIAL IN CONFIDENCE

Enviraf Project Ref: P0098 - 2018

BMA Document Ref: 6603/01/v1.2 October 2018

November 2018


V1.5 of 77 Enviraf Ltd/Cork City Council

This Report has been prepared by Enviraf Ltd and Berwick Manley Associates Ltd with reasonable skill, care and diligence within the terms of the agreement with the client and based on the agreed effort and resource commitment to the project. We disclaim any responsibility in respect of any matters arising outside this scope.



Contents

1 INTRODUCTION .............................................................................................................. 6

2 AUDIT TEMPLATE .......................................................................................................... 8

2.1 Introduction ............................................................................................................................ 8

3 KEY CHANGES SINCE THE 2015 AUDIT .................................................................... 9

4 LICENCE COMPLIANCE ISSUES ................................................................................ 11

4.1 EPA Site Visit and Inspection Ref SV02549 – May 2015 ....................................................... 11

4.2 EPA Site Visit and Inspection Ref SV08285 – December 2016 .............................................. 18

4.3 EPA Site Visit and Inspection Ref SV11398 – September 2017 ............................................. 20

5 REVIEW OF AER AND PREVIOUS AUDIT ................................................................ 24

5.1 Annual Environmental Reviews ............................................................................................ 24

5.2 Enviraf Site Visit and Audit, 2015 .......................................................................................... 25

6 AUDIT FINDINGS AND REVIEW OF DATA .............................................................. 30

6.1 Site visit and inspections of relevant operational files, drawings and data ......................... 30

6.2 Notes from interview with Site manager and key operational personnel ........................... 30

6.3 Notes from inspection of gas management system plant and equipment .......................... 31

6.4 Review and verification on annual system monitoring data ................................................ 40

6.5 Review and verification of operator performance criteria. .................................................. 40

6.6 Inspection of operator training records. ............................................................................... 40

6.7 Review of gas management system modifications and improvements. .............................. 41

6.8 Review of accident, incident and complaints records. ......................................................... 41

7 CONCLUSIONS AND RECOMMENDATIONS ........................................................... 42

7.1 Conclusions ........................................................................................................................... 42

7.2 Recommendations ................................................................................................................ 43

APPENDIX 1 Operating and monitoring data......................................................................... 45

APPENDIX 2 Landfill Gas Production Forecast (Gas Model) ............................................... 65

APPENDIX 3 Comparison of manual and continuous gas monitoring data ........................... 67

APPENDIX 4 Gas well dipping results ................................................................................... 73

APPENDIX 5 Comparison of the PRTR data ......................................................................... 75

APPENDIX 6 Power Station Performance 2015 - 2017 ......................................................... 76



List of Tables

Table 1 Source Information ....................................................................................................... 6

Table 2 Non-compliances and comments – May 2015 ............................................................ 12

Table 3 Non-compliances and observations – December 2016 ............................................... 19

Table 4 Non-compliances and observations – September 2017 .............................................. 21

Table 5 Flare and Engine Emissions ........................................................................................ 24

Table 6 Status of Mitigation (2018) After 2015 Recommendations ........................................ 25

Table 7 Review of operational files, drawings and data .......................................................... 30

Table 8 Personnel interview ..................................................................................................... 30

Table 9 Gas control infrastructure inspection .......................................................................... 31

Table 10 Review of annual monitoring data ............................................................................ 40

Table 11 Review of operator performance criteria .................................................................. 40

Table 12 Inspection of operator training records ..................................................................... 40

Table 13 Review of gas management system modifications ................................................... 41

Table 14 Review of accident, incident and complaints records ............................................... 41

Table 15 RAG criteria for gas wells assessment ..................................................................... 45

Table 16 Gas wells - 2016 RAG classification by phase ......................................................... 46

Table 17 Gas wells - 2017 RAG classification by phase ......................................................... 46

Table 18 Comparison of gas well RAG classification 2015 – 2017 by phase (numeric) ........ 47

Table 19 Comparison of gas well RAG classification 2015 – 2017 by phase (percent) ......... 48

Table 20 RAG classification criteria for gas monitoring boreholes ........................................ 49

Table 21 Gas monitoring boreholes – RAG classification 2016 ............................................. 49

Table 22 Gas monitoring boreholes – RAG classification 2017 ............................................. 50

Table 23 Trends on gas monitoring boreholes 2015 - 2017 .................................................... 51

Table 24 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4, numeric) ................................................................................................................................... 51

Table 25 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4, percent) .................................................................................................................................... 52

Table 26 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CO2, numeric) ................................................................................................................................... 53

Table 27 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CO2, percent) .................................................................................................................................... 54

Table 28 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4 & CO2, numeric) .......................................................................................................................... 55

Table 29 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4 & CO2, percent) ............................................................................................................................ 56

Table 30 Gas well dipping results – January 2018 .................................................................. 73

Table 31 Comparison of the PRTR data 2014 - 2017 .............................................................. 75



Table 32 Landfill gas power station performance 2015 - 2018 ............................................... 76

List of Figures

Figure 1 Gas Monitoring Borehole RAG classification 2016 – Blue Demons ........................ 57

Figure 2 Gas Monitoring Borehole RAG classification 2016 - Greenhills ............................. 58

Figure 3 Gas Monitoring Borehole RAG classification 2016 – Landfill Perimeter ................ 59

Figure 4 Gas Monitoring Borehole RAG classification 2016 – Park & Ride ......................... 60

Figure 5 Gas Monitoring Borehole RAG classification 2017 – Blue Demons ........................ 61

Figure 6 Gas Monitoring Borehole RAG classification 2017 – Greenhills ............................. 62

Figure 7 Gas Monitoring Borehole RAG classification 2017 – Landfill Perimeter ................ 63

Figure 8 Gas Monitoring Borehole RAG classification 2017 – Park & Ride ......................... 64

Figure 9 Landfill gas production forecast (phases 1-4) and current gas flow rate .................. 65

Figure 10 Landfill gas production forecast (historical phases i.e. P&R and Phase 5) ............. 66

Figure 11 Comparison of manual and continuous readings (methane – borehole 137) .......... 67

Figure 12 Comparison of manual and continuous readings (carbon dioxide – borehole 137) 67









Figure 21 Comparison of manual and continuous readings (methane – borehole LG12) ....... 72

Figure 22 Comparison of manual and continuous readings (carbon dioxide – borehole LG12).................................................................................................................................................. 72

Figure 23 Well dipping results – January 2018 ....................................................................... 74

Figure 24 Gas well temperature – January 2018 ..................................................................... 74

Figure 25 Power station performance 2015-2018 – monthly power generation ..................... 77

Figure 26 Power station performance 2015-2018 – cumulative power generation ................. 77



1 INTRODUCTION

This Report has been prepared jointly by Enviraf Ltd (Enviraf) and Berwick Manley Associates Ltd (BMA) for Cork City Council and follows the Kinsale Road former landfill (the Site) audit carried out by Enviraf’s Dr Lewicki on the 6th – 7th February 2018. The outcome of this visit was a comprehensive review of previous audit 20151 and later detailed data analysis of the gas control system.

The source documents provided by the Site management are listed in Table 1.

Table 1 Source Information

Review Source Report Title Date

Ref Origin

1.1 Cork City Council Kinsale Road Landfill, Waste Licence Register No: W0012‐03 Annual Environmental Report [Period covered: January to December 2016]

14‐Jun‐17

1.2 Cork City Council Kinsale Road Landfill, Waste Licence Register No: W0012‐03 Annual Environmental Report [Period covered: January to December 2017]

26‐Jul‐18

1.3 EPA Site Visit Report Ref SV02549 [by Linda Dalton, visiting on 26‐May‐15]

18‐Jun‐15

1.4 EPA Site Visit Report Ref SV08285 [by Caoimhin Nolan on 08‐Dec‐16] 31‐Jan‐17

1.5 EPA Site Visit Report Ref SV11398 [by Pamela McDonnell on 08‐Sep‐17] 18‐Sep‐17

1.6 Enviraf Audit Check_List_2018 07‐Feb‐18

1.7 Cork City Council Perimeter Gas Monitoring Data (Blue Demons, Park & Ride, Greenhills, Landfill North & South) 2016

17‐Jul‐18

1.8 Cork City Council Perimeter Gas Monitoring Data (Blue Demons, Park & Ride, Greenhills, Landfill North & South) 2017

17‐Jul‐18

1.9 Cork City Council Monthly Kinsale road Landfill (KRLF) Field Balancing Data 2016 02‐Feb‐18

1.10 Cork City Council Monthly Kinsale Road Gas Field Balance Reports 2017 02‐Feb‐18

1.11 Cork City Council Well Dip Records Kinsale Road 17‐Jul‐18

1.12 Cork City Council Quarterly Flare Service Records 2016 & 2017 19‐Sep‐18

1.13 Cork City Council Ambisense Continuous Gas Monitoring Data 2017 05‐Feb‐18

1 Berwick Manley Associates, ‘Kinsale Road Landfill, Cork, Republic of Ireland, Site Assessment, Landfill Status – Strategic Review’, Ref 6602/03/v2.0, January 2016 (Appendix 4)



1.14 Enviraf Photographs taken on site (06‐07 February 2018) 07‐Feb‐18

1.15 Cork City Council Photographs taken on site (20 September 2018) 20‐Sep‐18

1.16 Cork City Council Biogas Power Station Records 2016‐2017 07‐Feb‐18

1.17 Enviraf Annual Site Audit. Landfill Gas Control System 2015 Dec‐17

The remainder of this Report is set out as follows:

Section 2. Describes the ‘template’ adopted to steer the Audit.

Section 3. Briefly summarises key changes of the features and issues characterising the Site and its gas management operations since the last audit.

Section 4. Describes the licence compliance issues

Section 5. Provides succinct review of relevant points of the Annual Environmental Reports for years 2016 and 2017 and previous audit actions.

Section 6. Provides comprehensive review of the findings of the Audit and an interpretative commentary on the operating data for the gas management system (for years 2016 and 2017) provided by Cork CC.

Section 6. Gives conclusions and itemises recommendations to guide future Site audits.

Appendix 1. Analysis of the operating data provided by Cork City Council (CC).

Appendix 2. Gas production forecast based on theoretical gas model.

Appendix 3. Comparison of manual and continuous gas monitoring data.

Appendix 4. Gas well dipping results.

Appendix 5. Comparison of the PRTR data.

Appendix 6. Power station performance.

Elements of Enviraf Brief

BMA was invited by Enviraf to provide additional support during the preparation of the 2016 - 2017 Site audit of the closed and restored Kinsale Road Landfill. The scope of the works required was to carry out an objective review of the following:

Previous recommendations and actions in comparison to the current status as seen in audit visit of the 6th and 7th February 2018.

EPA site visit reports (three in number). The Annual Environmental Reports submitted by Cork City Council for the periods of

January to December 2016 and 2017.

The Fehily, Timoney Company (FTC) Risk Assessment of Landfill Gas Migration (Rev. 03, September 2013) in the context of gas readings from previous years and years 2016-17.



2 AUDIT TEMPLATE 2.1 Introduction A site-specific template was produced to steer the on-site inspection carried out by Enviraf. The Template identified 8 No. Key Aspects, as follows:

1. Site visit and inspection of relevant operational files, drawings and data.

2. Notes from interview with Site manager and other key operational personnel.

3. Notes from inspection of gas management system plant and equipment.

4. Review and verification on annual system monitoring data.

5. Review and verification of operator performance criteria.

6. Inspection of operator training records.

7. Review of gas management system modifications and improvements.

8. Review of accident, incident and complaints records.

These key aspects form the basis of a Spreadsheet template, used during the Audit, shown in 4.2, below.



3 KEY CHANGES SINCE THE 2015 AUDIT

The overall system concerning the number and position of gas wells and pipework has not changed since the last 2015 audit. For description see section 2.4 of the Annual Site Audit 2015 [1.17].

Following the Appendix 5 of the Annual Site Audit 2015 [1.17] and information received during the site visit on the 6th – 7th February 2018 the following observations were noted:

1. Significant repair works on gas collection system have been carried out as part of the long term maintenance and repair plan after the 2015 Audit and the February 2018 visit, namely:

- repairs and improving access to wellheads of the gas wells and monitoring boreholes - installation of small diameter bypasses on the manifold lines - sealing off numerous gas wells - lifting well heads and remaking the pipework on the wells that were subject to significant subsidence and crushing of the pipework due to the weight of concrete well covers - installation of valves on the dewatering wells thus eliminating air ingress and making the dewatering of gas lines more efficient and more user friendly - installation of valves on links between gas pipelines on Phase 4 and Phases 1 & 2 that made the field balancing easier by removing the crossover of the gas between the above Phases - well heads and pipework at Blue Demons: repairs and ongoing maintenance.

2. Strategy of gas management has been reviewed and adjusted to the current situation with due consideration of environmental and gas utilisation needs, namely:

- decreasing the overall (excessive) suction on the gas field in order to adjust the gas collection regime to the volumes of gas generated on site - adjustments of the gas wells with consideration of the oversized gas collection system - balancing the gas field with consideration of the gas quality satisfying the power station needs without compromising environmental control - redirecting all the gas into the “Good Gas” lines (except for Phase 2 wells, which are checked and monitored during the monthly field balancing. Phase 2 is then brought in to operation with the main gas field as required), which makes the gas balancing clearer and easier - the gas quality is maintained at concentration levels to enable successful operation of the power station and flaring of the gas in the event of the engine shut-down.

3. Following recommendations of the previous audit, the quarterly checks and maintenance of the gas compound, flare and dewatering vessels complete with (c/w) pumps (knock-out-pots [KOP]) have been documented.

4. Following recommendations of the previous audit, a survey (well-dipping exercise) of the accessible wells was carried out in January 2018.



5. Bringing adequate suction to Phase 2, independently of the remaining Phases. CCC

report that this work is complete – suction to phase 2 has been achieved via existing valve and manifold network.

Ongoing and progressing items at the time of the 2016-2017 audit were as follows (See also Table 7):

1. Gas infrastructure drawing update. The drawing used to date was not generated by the site surveyor, hence the delays with this report. It is understood that the solution is being sought by the Cork CC. CCC report that a final as built drawing for the entire site is not available, however, facility management and gas field operator are satisfied that the current drawing depicting the gas field infrastructure are accurate.

2. Inventory and review of the monitoring infrastructure at Blue Demons, Park & Ride and Greenhills. CCC reports that existing drawings are accurate. An asset register for same is currently (as October 2018) being complied.

3. Accumulation of the monitoring data and their comparison with the data gathered in previous years, to continue adequate assessment of the gas situation on site.

4. Consideration of the Park & Ride gas control system functionality review and possible tests with the purpose of adjusting the gas control strategy in this area. CCC report that the best fit scenario for gas field monitoring and operation at the Park and Ride is currently being employed. The gas field at the P & R is under constant negative pressure and the flow rate of extracted gas is circa 500 m3h-1. The building at the P & R is equipped with vent cowls, permanent CH4, O2 and CO2 alarms and is frequently monitored via handheld gas analysers. CCC are satisfied that this is the optimal operational strategy for the P & R and satisfies all safety, health and environmental requirements/obligations.

5. Selection of the most effective gas abatement strategy for the incombustible gas (including of biofilter, vent stack, etc.). Seeking an agreement with the EPA in regard to the selected application.

6. Development and update of the Explosion Protection Document for the site.

7. Safe access to monitoring locations for technicians and restricting public access to relevant parts of the gas control system.



4 LICENCE COMPLIANCE ISSUES

This Section of the Report examines each of the compliance issues related to landfill gas identified by the EPA during their site audit visits. The aim is to inform the reader on progress with mitigation measures implemented by Cork City Council. This section has been developed with the co-operation of Berwick Manley Associates Ltd (BMA).

4.1 EPA Site Visit and Inspection Ref SV02549 – May 2015

A Site inspection was carried out by the EPA (Inspectors Linda Dalton and Rebecca Connolly) on 26th May 2015 and was reported to Cork CC on 18th June 2015. The visit was scheduled and lasted for 4¾ hours.

The focus of the visit appears to have been divided between an inspection of the site (of part of the landfill (‘domed’ area)); water discharge points SD1 and SRP5; the Civic Amenity (CA) site) an examination of site monitoring (gas, leachate, surface water and ground water) as well as an inspection of site operational records.

Non-compliances and comments related to landfill gas were identified by EPA and these are summarised in Table 2.



Table 2 Non-compliances and comments – May 2015

EPA Ref EPA Comment / Corrective Action Condition Number

Comment

2. Landfill gas

2.2 There are two flares on site – 1250m3/hr flare collecting and combusting gas from the main waste body, and a 2500m3/hr flare collecting (though not combusting, and therefore considered non‐compliant with Condition 3.25.1(ii) of the licence) poor quality gas from the rest of the facility.

[NON COMPLIANCE]

3.25, 6.23 This operational practice stems from the fact that the gas quality from the Park & Ride site has always been very low in methane content. As per recommendations of the risk assessment, negative pressure should be maintained under the Park & Ride site hence the safety (priority) overweight the issue of venting incombustible gas. Due to the poor gas quality, combustion in a standard flare is not technically possible. It would be safer and more environmentally friendly to vent the gas through a biofilter to oxidise the residual methane, however changing the methane abatement technique need approval of the Agency. . If this option is not approved, a safer practice would be venting the gas through a devoted vent stack. Use of support fuel in accordance with the Licence condition 6.23.5 would be detrimental to the environment due to the carbon footprint and not economically justified. “Cost‐benefit‐analysis” should be carried out and discussed with the Agency.

See Section 6.3 and Appendix 2 for consideration of the gas quality (0.7% vv) and volumes (<10 m3h‐1 if converted to 50% methane content).

PRIORITY




Comment

2.8 The licensee was instructed in previous site inspection reports that balancing shall include monitoring, and recording of, valve position, gas quality, gas pressure and flow at the wellheads and the manifold. The licensee advised during this site visit that infrastructure is not in place at the wellheads to allow for the monitoring of gas flow and that the possibility of monitoring flow at the manifolds is currently being investigated and will be addressed in the 2015 annual independent review of landfill gas management required under Condition 6.23.9

The licensee shall submit the 2015 annual independent review of landfill gas management as a new licensee return for review by the Agency within one month of completion. The matter of monitoring of landfill gas flow in the gas fields will be considered by the Agency at this time. In the interim, the licensee shall ensure that gas balancing records include all of the information specified above (with the exception of flow) unless otherwise agreed with the Agency.

[COMMENT / CORRECTIVE ACTION]

1.5, 6.8, 6.23, 23.7

Under review as part of the annual independent review of landfill gas management. Condition C.1.2 of the Licence requires only continuous flow measurement on the outlet (but not on the inlet) on both flare and utilisation plant. Measurement of the gas flow at well heads is not technically possible as the design of the gas collection system has not considered such operation. Facilitating flow measurements would require digging in the site cap, compromising its integrity and exposure of gas collection pipework. Due to the configuration of the pipework on the manifolds, flow rate measurement on manifolds would be flawed, as the design did not foresee such operation. An attempt can possibly be made on the small diameter bypasses. However this will entail installation of several dozen sampling points, would be a laborious practice, working in confined space with increased health and safety risk for the personnel. See Appendix 1. The analysis of operational data has been carried out on the basis of the 2016 and 2017 gas quality and pressure data. Recommendations contain remarks about recording valve positions. Clarification and “cost‐benefit‐analysis” should be carried out. Agree with the Agency and adopt practicable solution.

2.9 The licensee shall ensure that surface VOC emissions surveys are completed twice/year as required in Condition 6.26.2 unless otherwise agreed with the Agency.

6.26.2 Due to the fact that the site is closed and the gas collection system operates satisfactorily, decreasing of the VOC surveys may be justified. Agree with the Agency the frequency of surveys.




Comment


2.10 A number of action items which were raised in the last site visit report issued on the 10/04/15 remain outstanding as follows:

1. The licensee shall submit a map of all landfill gas monitoring wells on site, labelled in accordance with landfill gas balancing records etc., in response to CI000993.

CI A011187 – due date 24/04/2015 Submit a map of all landfill gas monitoring wells on site


CCC report that a final as built drawing for the entire site is not available, however, facility management and gas field operator are satisfied that the current drawing depicting the gas field infrastructure are accurate.

CCC report that existing drawings for monitoring infrastructure are accurate. An asset register for same is currently (as of October 2018) being complied.

2.10 2. A landfill gas risk assessment was completed in September 2013. The licensee shall provide a schedule detailing what actions have been taken in respect to Key Recommendations 1(d), 2, and 3(c) to (f) inclusive. Where the actions have not yet been fully completed, a timeline for completion shall be provided. This information shall be submitted in response to CI000993. CI A011188 – due date 24/04/2015 Submit a timeline for completion of the recommendations of the Landfill Gas Risk Assessment [COMMENT / CORRECTIVE ACTION]

As confirmed in the most recent audit meeting between the Agency and the Cork City Council, response to these points should close the issue of the 2013 Landfill Gas Risk Assessment.

The landfill gas risk assessment was addressed in the independent review of landfill gas management system (LFGMS) in 2015, in which points raised by the authors were addressed.

1(d) – comprehensive operating manual for the facility supplemented with appropriate staff training – the manual was submitted with the 2015 independent LFGS review

2(a) – undertake monitoring of water levels in LG15‐19 and DP‐4 – the issue subsequently was discussed with the Agency and the CCC has no plans to revisit this point at this time

2(b) – install continuous monitoring for methane gas (and carbon monoxide within buildings) – monitoring at Park & Ride has been operational. The recommendation regarding “carbon




Comment

monoxide” is clearly a misprint or error. Most likely it should read “carbon dioxide”. There is no point of monitoring carbon monoxide in the buildings, as this gas is present in landfill gas only in case of underground fires. Carbon monoxide monitoring may be justified where gas boilers or coal/wood stoves are used.

3(a) – apply for technical amendment to WL condition 3.25(ii) to accommodate changes in calorific values in landfill gas – addressed in point 2.2 above and recommendations regarding application technologies other than flaring or commercial utilisation of landfill gas.

3(b) – ensure that future capping works/designs accommodate current and future conditions (under both operational and emergency situations), in particular where extraction may be less than landfill gas production – completed. The situation on site is inclined to the opposite, i.e. oversized gas collection system may extract more gas than there is generated, if not balanced properly.

3(c) – develop and calibrate landfill gas prediction models – completed with the independent review of LFGMS 2015

3(d) – plan for modification to current active gas collection infrastructure – addressed in the independent review of LFGMS 2015; ongoing activity.

3(e) – develop extraction criteria for the Park and Ride facility so that negative pressure is present at all times – completed and confirmed with the independent review of LFGMS 2015. Adopting this recommendation caused non‐compliance issue with the WL condition 3.25(ii), as the extracted gas cannot be flared due to minute methane concentration. See point 2.2 above. This point is addressed in the recommendations of the 2016‐2017 review.




Comment

3(f) – carry out structured auditing and balancing of the gas extraction system at regular intervals. Ensure that gas extraction is greater than or equal to gas production at the site – completed and ongoing; confirmed by the independent review of LFGMS 2015, 2016‐2017. Adopting this recommendation caused non‐compliance issue with the WL condition 3.25(ii), as the extracted gas from certain parts of the LFGMS cannot be flared due to minute methane concentration. See point 2,2 above.

2.10 3. The licensee shall ensure that the leachate extraction system, in particular the wells now installed in the centre of the dome area, are fully operational and leachate levels in the waste body are minimised to prevent the risk of dissolved gas migrating from the facility and allow for the adequate operation of the landfill gas extraction system.


Leachate extraction system woks satisfactorily and leachate levels are maintained at practicably achievable minimum.

Correspondence regarding details of leachate borehole wells was sent to the Agency in April and July 2015.

See Appendix 4 for recent well dipping data.

Landfill gas system is operating correctly in balance with the environmental and gas utilisation needs.

2.10 4. The licensee shall continue monitoring of groundwater quality to the east of the landfill for dissolved methane on a quarterly basis in wells OB3, BR3, NW6, and one well located outside of the known leachate plume to the east of the facility at minimum. The results of dissolved gas monitoring shall be submitted to the Agency as a new licensee return within one month of completion of each monitoring event unless otherwise agreed.


This point is ongoing. Suitable services are being sought for.




Comment

6. Site specific issues

6.1 The licensee has not yet submitted the 2014 Annual Environmental Report. This is non‐compliant with Condition 11.10 of the licence.

[NON COMPLIANCE]

11.10 In respect of the LFGMS an addendum to this (2016‐2017) independent review is proposed to close the corrective action, providing that the LFG operational and monitoring data are available.

CCC report that as of September 2018 – all reports mentioned have been submitted.

6.2 The licensee shall label all monitoring points as required in Condition 3.6 of the licence.


This issue has since been addressed and during the inspection in February 2018 all checked monitoring points were labelled. As the paint deteriorates with time, periodic checks are carried out and any faults rectified.



4.2 EPA Site Visit and Inspection Ref SV08285 – December 2016

A Site inspection was carried out by the EPA (Inspector Caoimhín Nolan) on 6th December 2015 and was reported to Cork CC on 31st January 2017. The visit was announced and lasted for just over two hours.

The focus was on site inspection and no records or documents were examined.

Reference is also made to other aspects and issues in line with standard Visit Report template used by the EPA. As such, some of the non-compliances and advisory comments made in the previous Visit Report (q.v. 4.1, above) are reported to have been adequately addressed.

The landfill gas issues were raised amongst other site specific issues, as summarised in Table 3.



Table 3 Non-compliances and observations – December 2016


Comment

2. Landfill gas

2.1 Construction work was noted to be taking place on‐site which the landfill manager indicated was related to a biofilter (which was ultimately intended for handling landfill gas). The use of such a biofilter has not been agreed to by the Agency, and the licensee is reminded of the need to get agreement from the Agency for any proposed use of such a structure for the treatment/handling of landfill gas, whether this be on a trial basis or for more long‐term use. [COMMENT / CORRECTIVE ACTION]

6.23.4, 6.23.5

The licensee approach is commendable as this action is addressing points 2.2 and 2.10, raised in the SV02549 report. However, the requirement for EPA written approval for the bio‐filter then under construction is necessary.

PRIORITY

2.2 The precise set‐up with regard to the operation of the gas flares and utilisation plant was not checked during the site inspection, however abstraction and utilisation was noted to be taking place at the time using the 0.5 MW engine. No landfill gas odours were detected on‐site during the site inspection.


No action recommended by the Agency. Confirmation of balance between the environmental and gas utilisation requirement.

6. Site specific issues

6.1 While the 2015 AER relating to the facility has been received and uploaded onto the EPA website, the 2014 AER is not available on the website. The licensee should submit this report, or provide any necessary clarifications/updates as necessary, to facilitate publication of the 2014 AER onto the Agency's website.

[NON COMPLIANCE]

11.10 In respect of the LFGMS an addendum to this (2016‐2017)independent review is proposed to close the corrective action, providing that the LFG operational and monitoring data are available. CCC reported that as of September 2018 – all reports mentioned have been submitted.



4.3 EPA Site Visit and Inspection Ref SV11398 – September 2017

A Site inspection was carried out by the EPA (Inspector Pamela McDonnell) on 8th September 2017 and was reported to Cork CC on 18th September 2017. The visit was announced as part of the OEE 2017 Enforcement Plan2 and lasted for just over 5½ hours. The facility manager was not among the Licensee personnel present on the day.

The focus of the EPA audit was an inspection of most of the Site, an examination of two reports (AER 2016 and a 2013 gas risk assessment3), gas balancing data and monitoring point layout plans.

The Site areas examined were:

The flare compound The civic amenity site The old composting area The leachate lagoons and surface water lagoons The reed bed discharge point The leachate conditioning plant The gas bio-filter (not in operation) A sample of on-site and off-site gas wells, leachate wells and groundwater wells Gas Manifold 1

Non-compliances were raised in relation to flare operation, the bio-filter, waste tonnages, bunding and delays in the preparation of reports. The issues and additional observations made by the EPA related to landfill gas are summarised in Table 4.

2 This introduces a requirement for the EPA to consider Health & Safety and Incident Prevention issues during the Site visit 3 Fehily Timoney, Risk Assessment of Landfill Gas Migration (WP 4), Sep 2013



Table 4 Non-compliances and observations – September 2017


Comment

2. Incident Prevention

2.1, 2.2 Establish a Fire Prevention Plan if one is not already in place. Ensure that all relevant personnel are aware of the location and contents of the Fire Prevention Plan at all times. Maintain training records accordingly. The Agency may follow up on this matter at any time.


Action ongoing.The tenders for Fire Prevention Plan and Explosion Protection Document is in process.

PRIORITY

2. Landfill gas

4.1 The licensee must get agreement from the Agency before any further works in relation to the biofilter is carried out and before any use is made of the biofilter or any other infrastructure in the biofilter compound, whether this be on a trial basis or more long‐term. The licensee shall physically disconnect the biofilter from the landfill gas network immediately and receive agreement from the Agency before any reconnection to the network is made. The Agency may follow up on this matter at any time.

[NON COMPLIANCE]

3.2 It is more environmentally friendly to process the gas through the biofilter rather than vent it directly into the atmosphere. The poor quality gas from part of the gas field and the Park & Ride extraction system is not combustible in a standard flare. The requirement for EPA written approval for the bio‐filter then under construction is necessary to be compliant. The biofilter has been disconnected since.

PRIORITY

4.2 Please note that in accordance with Condition 6.23.5, where alternative treatment techniques are to be employed for the management of poorer quality landfill gas, such techniques must have the written prior approval of the Agency.

[NON COMPLIANCE]

3.25 & 6.23 The requirement for EPA written approval for the bio‐filter then under construction is necessary to be compliant.

PRIORITY




Comment

4.4 Repair the pressure sensor on the inlet to the flare fan


Completed since. Noted in the 2016‐2017 independent LFGMS audit.

4.8 Submit copies of the 2016 VOC monitoring reports via licensee return by the 2nd October 2017.

The licensee is reminded that biannual VOC monitoring is required in accordance with condition 6.26.2(iv). Any amendment to this monitoring frequency must be approved by the Agency in advance, in accordance with condition 6.8.


6.8 Due to the fact that the site is closed and the gas collection system operates satisfactorily, decreasing of the VOC surveys may be justified. The frequency of surveys should be agreed with the Agency. See also point 2.9 of the SV02549 report.

4.9 The independent annual review of the landfill gas management system required by Condition 6.23.9 is outstanding for 2014, 2015 and 2016.

[NON COMPLIANCE]

6.23.9 The current independent annual review of the LFGMS report covers years 2016 & 2017. The 2015 report has been submitted. In respect to the 2014 of the LFGMS an addendum to the 2016‐2017 report is proposed to close this corrective action, providing that the LFG operational and monitoring data are available. CCC reports that as of September 2018 – all reports mentioned have been submitted.

4.9 Submit the outstanding reviews as a response to CI000993, Action No: A017876.


Since the CI000993 was raised, (26.05.2015) the optimisation of the LFG extraction system took place and this point is closed.

A meeting with the Agency would be beneficial to clarify and close the issues.

4.9 It is also noted that an update is required in relation to the following actions which were noted in site visit report SV02549:

• Progress on the actions taken/to be taken in respect of Key Recommendations 1(d), 2 and 3(c) to (f) inclusive, as outlined in the

As confirmed in the most recent audit meeting between the Agency and the Cork City Council, response to these points should close the issue of the 2013 Landfill Gas Risk Assessment.

Since this point was raised, all issues were completed and closed.




Comment

September 2013 Landfill Gas Risk Assessment. Where actions have not been fully completed, a timeline for completion shall be provided. The information shall be submitted in response to CI000993, CI Action A011188 by the 2nd October 2017.


See also details in the point 2.10 in SV02549 report above.

4.9 It is also noted that an update is required in relation to the following actions which were noted in site visit report SV02549:

• Progress on the quarterly assessment of methane and carbon dioxide (see Request for Information RI004649 in relation to Licensee Return LR18528) on a quarterly basis in wells OB3, BR3 and NW6, and a minimum of one well located outside of the known leachate plume to the east of the facility. Methane and carbon dioxide monitoring for these wells to date shall be submitted to the Agency as a new licensee return by the 2nd October 2017, and each monitoring event thereafter shall be reported within one month of completion unless otherwise agreed.


This point is ongoing. Suitable services are being sought for.



5 REVIEW OF AER AND PREVIOUS AUDIT 5.1 Annual Environmental Reviews Gas monitoring data quoted in the 2016 and 2017 AERs are consistent with the analysis carried out further in this report (see Appendix 1), as they are derived from the same raw data. Both AERs report duly all migration and non-compliances incidents. Both Park & Ride and Blue Demons areas are under active gas extraction regime in order to control the situation. Based on the historical information and previous studies, it cannot be excluded that these both areas as well as other borehole locations (Greenhills and Landfill North and South) can be subject of locally generated gas (i.e. there is a possibility that the gas is generated in-situ). As long as monitoring is carried out, risk assessment reviewed on regular basis and reported, the Agency should be satisfied that all possible efforts are put by the Cork City Council to maintain the best possible control over the gas.

All other issues, discussed in the AER generally confirm that Cork City Council has emissions and environmental burdens under control and compliant with Licence conditions. However, the external reports4 on emissions monitoring for the flare and engine show slightly deteriorating performance in 2017 compared to 2016 – see Table 6 – figures marked in red are compliant albeit statistically approaching the limit.

Table 5 Flare and Engine Emissions

Flare Emissions [mg/m3]5 Engine Emissions [mg/m3]6

Parameter Limit 13th Jan 177 14th Dec 17 Parameter Limit 13th Jan 178 14th Dec 17

CO 50 2.3 ± 2.8 14.5 ± 3.3 TPM 130 2.5 ± 0.4 2.5 ± 0.4

NOx 150 93.5 ± 7.9 139.6 ± 12.5 CO 1400 707.1 ± 39.9 1247.8 ± 72.8

TVOC 10 4.3 ± 0.6 4.1 ± 0.6 NOx 500 491.7 ± 36.6 436.4 ± 33.1

HCl 50 1.3 ± 0.0 <0.5 ± 0.0 HCl 50 <0.2 ± 0.0 <0.3 ± 0.0

HF 5 2.8 ± 0.1 <0.5 ± 0.0 HF 5 <0.3 ± 0.0 <0.3 ± 0.0

SO2 - 22.5 ± 8.5 80.5 ± 11.2 TA Luft Organics

20 <0.7 ± 0.1 <0.8 ± 0.2

SO2 - 421.5 ± 24.6 228.8 ± 14.4

4 Air Scientific Ltd, Air Emissions Compliance Monitoring Emissions Report, 30 January 2017 and 21 March 2017 5 Rounded to 1 significant figure 6 Ibid. 7 Given in the 2016 AER 8 Ibid.



5.2 Enviraf Site Visit and Audit, 2015

The previous independent audit carried out by Enviraf concluded with a list of recommendations (q.v. section 6.2) to enhance operational effectiveness and move towards full Licence compliance. Taking into account the status identified following the 2017 independent audit (also by Enviraf), the current situation is summarised in Table 6.

The 2015 Audit report (q.v.) also contains great detail of numerous gas management system issues, improvements and recommendations which should be read in conjunction with the details given in Table 6.

Table 6 Status of Mitigation (2018) After 2015 Recommendations

Ref Detail Mitigation Progress Comments/Actions

Major Points

1 Maintain and use consistent database for the gas management system

Reviewed and completed

Continue annual checks.

2 Continue updates of the gas infrastructure plans

Reviewed and ongoing Check annually that all issues are adequately documented

3 Continue with the long term maintenance programme for the gas extraction and monitoring infrastructure, including periodic update of inventory and documentation of any significant changes

Reviewed and ongoing Check annually that all issues are adequately documented

4 Continue with regular flares' service Documented, reviewed and ongoing.

Continue annual checks

5 Continue search for as‐built documentation that was not available during the audit

None yet obtained Unlikely to be found

6 Consider venting gas through a purpose‐designed vent stack rather than through a flare stack

None yet made Requires further review and discussion with Cork City Council and the EPA

7 Ensure adequate environmental control by regular data reviews and adjustments of the gas extraction system

Reviewed and ongoing. Correct balance between environmental (emissions) control and commercial use of gas has been maintained.

Keep EPA informed

8 Mark on gas records valve position and connection arrangement to good or bad line

Recording vale positions outstanding. Marking connections to Good or Bad Line may not be needed since all gas (except of Phase 5) goes into Good Gas system

Gas wells may need decommissioning or isolating and making safe by elimination of gas escapes and air ingress, as well as ensuring that they do not pose unacceptable risk for site personnel and visitors.




9 Investigate any transgressions found during monitoring

Reviewed and ongoing. Part of the 2016‐2017 report.

Keep EPA informed. Review risk assessment on regular basis.

10 Review functionality of relevant infrastructure flagged above by testing

None yet made Devise and seek approval for tests on Park & Ride and Blue Demons sites

11 Review passive building protection in the Park & Ride area and the purpose of running active gas extraction by series of tests

None yet made Devise and seek approval for tests on Park & Ride and Blue Demons sites

12 Review continuous gas warning system in the Park & Ride area

None yet made Install data logger for alarms

13 Consider installation of data logging sensors in the Park & Ride area

None yet made Install data logger for alarms

14 Consider written instruction for the Park & Ride users

None yet made Identify where responsibility lies

15 Review the ATEX related issues on site ‐ safety signs, Explosion Risk Assessment, Explosion Protection Document, access restrictions to certain areas

None yet made Consider developing and updating the Explosion Protection Document

16 Ensure safe access to monitoring locations Progressing and ongoing Review well‐head repairs, manifold access ladders and access restrictions for the public

Specified Corrective Actions

41f 11 B1(e) Devise a plan and investigation to improve gas management in bad gas system

including avoidance of direct venting of gas [Park and Ride Site]

17 Identify connections of the gas wells to bad gas system during routine adjustments.

The aim was to clarify connections in the Bad gas system during ongoing gas wells adjustment process

The revised gas treatment strategy (all gas to Good system for the power station) renders this largely superfluous

18 Adjust the wells to achieve reasonable stability of gas quality and flow rate of operational wells.

Adjusted to some 200 m3/h flow with a sustainable concentration of 47% CH4

No obvious environmental (migration/surface emissions) or odour issues – but further data review required

19 Analyse gas parameters and long term performance of gas wells connected to bad gas system.

May not be needed since all gas (except of Phase 5) goes into Good Gas system

Gas wells may need decommissioning or isolating and making safe (as above in point no. 8)

20 Consider reassessing of the active gas extraction system on the Park & Ride site [Switching it off]

Set up a trial with approval of EPA and site operator to assess

Requires discussion and approval of the EPA and P&R operator.




feasibility of cessation of active gas abstraction

Basis of trial:

Establish baseline (gas abstraction and monitoring parameters)

Carry out a risk assessment

Shut down gas abstraction and isolate for 24 hours

Monitor and confirm safe before permitting use of buildings

Monitor at all available locations to assess changes

If safe, extend the shut down and continue monitoring

If unsafe, restart gas abstraction

21 Select an alternative gas abatement technique; e.g. bio‐filter, thermal oxidation, low calorific value gas flare [Ref existing 0.7% CH4, 3.6% CO2 and ~750 m3/hour

Requires discussion with Cork City Council and approval of EPA Financial burden may prove decisive in rejecting this search for alternatives

22 Carry out feasibility study on selected technologies [efficiency of destruction of gas, reliability, O&M long term (aftercare) period, capital and O&M costs, carbon footprint]

Consider after in principle approval of the EPA and CCC (see 21)

23 After approval of the technology carry out a trial on site to prove the full scale installation.


24 After successful trial seek financing and implement the technology on site, maintaining correct gas parameters.


41f 15 C3 Identify options for mitigation if gas detected

25 Implement emergency procedures in accordance with the gas management plan: ‐ Analyse gas monitoring data concerning the incident; ‐ Verify information; ‐ If necessary increase monitoring frequency or employ continuous gas monitoring; ‐ Carry out information gap analysis and obtain missing and supplementary data.

These recommendations are related to the framework gas management plan. It is not possible to define a single plan of action, as events may concern different parts of the site and its

In the case of establishing of the source of the gas, it may be necessary to consider specialised gas analysis to determine the source, such as carbon‐isotope and/or trace components ‘finger printing’




Include meteorological data (atmospheric pressure, rainfall, temperature); ‐ Identify potential pathways of migrating gas; ‐ Identify receptors that may be affected by the migrating gas; ‐ Confirm the source of the gas ‐ anthropogenic or naturally occurring; ‐ Identify other possible sources of gas presence in the ground in the affected area; ‐ Carry out risk assessment based on the data available; ‐ If anthropogenic ‐ implement mitigation; e.g. adjust gas extraction system, protect receptors using active or passive barrier; ‐ If naturally occurring ‐ notify relevant bodies that may be responsible for gas presence; ‐ Check the effectiveness of implemented actions; ‐ Modify actions accordingly if necessary to mitigate the incident; ‐ After regaining control over the gas, instigate post‐event monitoring.

surroundings. Each case of detected gas migration should be treated on strictly individual basis and individual risk assessment of the situation.

41h6 1 A6 Clarify records of flow lines to Good or Bad gas systems

26 During the next gas infrastructure plan update, the lines should be clearly marked on the drawings and in situ

May not needed since all gas goes into Good Gas system

All redundant pipe work and infrastructure should be safely and permanently decommissioned

41f 1 (–) Ensure that all landfill gas generated at the facility is either utilised or flared

27 After changing the strategy for gas management, the good quality gas now supplies a 0.5 MWe power station

This action has been successfully implemented.

41h 18 1 B1(x) Complete 'gap analysis' on understanding of gas migration

from any part of the site

28 Observations during data gathering exercise for the 2016‐2017 audit concur with the conclusions in section 3.4 of the BMA report9

9 Berwick Manley Associates, Site Assessment Landfill Status – Strategic Review, Ref 6602/03/v1.1, October 2015




41h 19 1 B2 Complete a Gas Risk Assessment based on a conceptual model considering all

possible migration areas and findings of the independent review

29 Gather more evidence supporting observations and conclusions raised in the BMA report [on FTC work ] and review it in due course

The site conceptual model is largely complete and only requires ‘fine tuning’

Further interpretation in the light of performance of the gas management system is now required to support observations and conclusions in the BMA report10

10 Ibid.



6 AUDIT FINDINGS AND REVIEW OF DATA 6.1 Site visit and inspections of relevant operational files, drawings and data

Table 7 Review of operational files, drawings and data

Observations Improvement recommendations

Operational files for gas management system in place:

- gas wells adjustment records - gas compound data - gas monitoring data - service records of the gas compound - personnel training records

Recommendations from the 2015 audit followed. Data in place.

None.

Drawings of the gas infrastructure in the updating process.

The drawing used so far was not generated by the site surveyor, hence the delays. It is understood that the solution is being sought by the Cork CC.

Complete the drawings update.

6.2 Notes from interview with Site manager and key operational personnel

Personnel interviewed: Kevin Ryan (Site Manager) and Robin Bateman (Maintenance and Monitoring Technician)

Table 8 Personnel interview


Since the 2015 survey certain historical information regarding construction details of the gas control system was sought for with negative result.

As the information is not available, a stock-taking exercise is recommended.

The management structure has been reviewed and any changes reported to the relevant authorities.

None




Reporting incidents and data usage. No major issues identified since the action was logged.

None

Adjustment strategy of the gas collection system in the view of operating 0.5 MW power station.

None.

Successful change achieved without compromising environmental control.

6.3 Notes from inspection of gas management system plant and equipment

Table 9 Gas control infrastructure inspection


Gas parameters in the engine supply line:

CH4 42.8% CO2 36.8% O2 0% flow – unknown, engine operating at 295-320 kW/hr.

The strategy of gas field balancing changed successfully to match the power station needs and environmental control.

None.

Keep recording the data for further analysis.

Safety signs at the gas compound entry are incomplete.

Update safety signs in regard to the ATEX requirements, i.e. entering the area where potentially explosive zones exist.

Part of the Explosion Protection Document (EPD) review.

Mix of ATEX and non-ATEX equipment in the gas booster container.

Check equipment documentation and refer to manufacturer if necessary.

Include the gas booster container into ATEX risk assessment and Explosion Protection Document update.




Lock fitted on the flare stack door.

None.

Recommendation completed.

Emergency stop on emergency flare difficult to reach from outside.

Make the emergency stop easily accessible from outside the stack.

Single valve isolation on emergency flare

The pipe should be blanked off to avoid accidental air intrusion in case of the valve leak.




Inlet Pressure transmitter on 1250 m3h-1 flare in working order.

None.

Repaired.

Flowmeter on the 1250 m3h-1 flare shows 0 m3h-1.

Repair and calibration are beyond economical repair.

Apply periodic manual measurements and include in the monthly reports.

Note Condition C.1.2 of the Licence that requires only continuous flow measurement on the outlet (but not on the inlet) on both flare and utilisation plant.

Flare 2500 m3h-1 was venting 780 m3h-1 of lean gas, containing 0.7% methane, 16.2% carbon dioxide and 0.1% oxygen at -250 mbar suction.

Consider available technologies for poor quality gas abatement, e.g. biofilters.

Consider venting the poor quality gas through purpose designed vent stack.

Agree with the EPA and obtain written approval.




Flare servicing records available. Dates of servicing:

3&4 October 2016 20 January 2017 16 & 17 May 2017 13 October 2017 15 December 2017 29 & 30 March 2018 23 May 2018

None.


Ongoing activity.

HDPE pipework on pressurised gas line to the engine. No flame arrester fitted.

Ongoing activity. Flame arrester purchased and delivered. Contractor selected. Install after the steel pipework is place.

Gas Field infrastructure (Phase 1 - 5)

Well head after repair.

None.

Recommendation completed. 16 No gas wells repaired.

Ongoing activity.




Safety signs at manifolds missing. The only sign warns against confined spaces.

Phase 4 Manifold 2

Phase 4 Manifold 1

Phase 5 Manifold 2

Update EPD and install.

If the intention is to avoid unnecessary alerting the visitors and putting the warning signs inside the enclosures, the manifolds would need secure and lockable fencing making access to the area more difficult for unauthorised persons.




Small diameter bypasses fitted to improve well adjustments.

Bad gas lines isolated.

View from inside gas manifold

None.


Phase 5 connected to the active gas control system on the 21 October 2016 (bad gas line).

Gas parameters on the 6th Feb 2018: CH4 35.9%, CO2 15.2%, O2 5.0% Static Pressure 1.9 mbar.

Install sampling point for flowmeter and include gas flow measurement into the monitoring.

Some gas well connections unclear. Continue with the stock-taking of the LFGCS and update the drawing accordingly.

This is part of the long term of the ongoing maintenance programme.




Park & Ride

Calibration on the gas alarm system overdue.

No access to switchgear room for checks.

Calibrate the gas alarm system ASAP.

Venting unit switched off. None.


Gas reading at the sampling point near pumps’ electrical box CH4 0%, CO2 0.4%, O2 19.9%. suction 97 Pa (0.97 mbar)

Carry out experiment with switching of the gas extraction system under control as described in the 2015 Audit.

On the landfill side (across the road) leak on the gas main – missing sampling point.

Repair or seal off.

Once sampling point fitted – check periodically the gas flow rate and quality.




Blue Demons

Pipework and wellheads exposed. Consider burying the pipework and protecting the wellheads with concrete rings to prevent unauthorised access.

Up to 20% CH4 measured on wells during the visit. No suction.

Review the gas control strategy for Blue Demons area and agree with the Agency.

Repairs on damaged gas collection system completed. Wells marked.

None.


Greenhills

Boreholes inspected. No changes since last audit. Review of functionality and repairs included in the ongoing maintenance programme.

None.





Venting trench boreholes localised and found marked. (Just GT5 shown on the photo)

None.


Flooded venting trench boreholes make some of the gas readings void. Historical information (anecdotal, not documented) indicates poor quality construction of the trenches.

Extensive work was carried out by the Cork City Council on this area, including installation of gas alarms in a number of houses, installation of numerous gas wells for monitoring throughout the estate and ‘gas cut-off trench’ on the landfill site, immediately adjacent to Greenhills estate. Gas fingerprinting in the past was deemed inconclusive. It is deemed that much of the gas is generated “in situ”.

Continue monitoring, regular reviews of risk assessment and report to the Agency any potential issues identified.



6.4 Review and verification on annual system monitoring data

Table 10 Review of annual monitoring data


Monitoring and gas well adjustment records have been collated, analysed and interpreted. This includes all wells, with open and closed valves. Pressure records available.

While taking gas well readings mark in comments on gas records sheets: - valve position - low diameter bypass connection.

Analysis of the data follows in Appendices.

6.5 Review and verification of operator performance criteria.

Table 11 Review of operator performance criteria


0.5 MW/hr power station operational.

The power station has been operating successfully in 2016, 2017 and 2018, indicating correct adjustments made to the gas collection system.

No surface emissions nor odour incidents reported. Balance between gas supply to the power station and environmental control achieved and maintained.

None.


6.6 Inspection of operator training records.

Table 12 Inspection of operator training records


Personnel training records readily available.

Training carried out:

2016 – monthly refresher training operation and housekeeping

None.




Robin Bateman (Cork City Council), Anthony Power (Irish Biosystems Ltd),

2017 - monthly refresher training operation and housekeeping

Robin Bateman (Cork City Council), Anthony Power (Irish Biosystems Ltd),

6.7 Review of gas management system modifications and improvements.

Table 13 Review of gas management system modifications


Covered in the inspection of the gas control infrastructure

Keep the records of changes documented and updated.

6.8 Review of accident, incident and complaints records.

Table 14 Review of accident, incident and complaints records


No issues reported None



7 CONCLUSIONS AND RECOMMENDATIONS 7.1 Conclusions

1. Long-term maintenance and repair plan for landfill gas collection system and monitoring infrastructure has been implemented and keeps progressing well.

2. Changing strategy of gas extraction regime proved successful and the power station is running with minimal interruptions.

3. Gas quality increased from 27% CH4 (2017) to 42% CH4 (2018) and flow reduced

from 533 m3h-1 to average 235 m3h-1 without compromising environmental control.

4. Improvement was noted on the Red-Amber-Green (RAG) classification of the gas wells.

5. Improvement was noted on the monitored areas – Blue Demons, Greenhills, Landfill

Perimeter, Park & Ride.

6. Improvement was noted on documenting flare and KOP servicing.

7. Non-compliance issues are being investigated and addressed.

8. Information of the gas management system is in need of periodic updating (e.g. infrastructure maps, gas well connections, database, gas management plan, emergency procedures etc.), this issue has been addressed in the recommendations below.

9. Some part of the infrastructure is in the need of inventory and review (e.g. Blue Demons, Park & Ride, Greenhills) due to changes over time and lack of documentation as built.

10. Certain safety issues related to gas need addressing. These have been listed in the

recommendations below.

11. As stated below in the recommendations section, some interpretation of the data gathered in the past may not be 100% correct and further evidence to support this observation is being gathered.

12. The well dipping results indicate good functionality of the accessible wells and relatively low temperatures, indicating slow gas production in Phase 4.

13. Comparison of the PRTR data 2014 – 2017 show that the site is well below the limits stipulated for landfills.

14. Surface emission reports do not indicate VOC emissions through the cap. This indicates adequate gas control and good containment of the site.



7.2 Recommendations

Specific recommendations are detailed and contained in Sections 5 and 6.

Major points extracted from these sections:

o Redundant gas wells may need decommissioning or isolating and making safe as well as all redundant pipe work and infrastructure

o Devise and seek approval for tests on Park & Ride and Blue Demons sites.

Once the approval is granted, carry out experiment with switching of the gas extraction system under control

o Install data logger for alarms at Park & Ride buildings o Develop the Explosion Protection Document

o Update safety signs after EPD is developed o Keep reviewing well-head repairs, manifold access ladders and access

restrictions for the public o Keep updating the Emergency Procedures

o Further interpretation in the light of performance of the gas management

system is now required to support observations and conclusions in the BMA report

o Update and complete drawings of the landfill gas infrastructure o Complete stock-taking exercise of the gas control infrastructure where

original information is missing o Make the emergency stop easily accessible from outside the flare stack in

the gas compound

o Blank off the gas supply pipe in the gas compound to avoid accidental air intrusion in case of the valve leak

o Repair and calibrate the flow meter in the gas compound if economically

viable

o Consider available technologies for poor quality gas abatement, e.g. biofilters and agree the implementation with the EPA. Carry on with the biofilter trials after getting approval from the Agency,

o Consider venting the poor quality gas through purpose designed vent stack

o Change the HDPE pipework delivering gas to the engine to steel and fit

flame arrester (in hand)



o Install sampling point for flowmeter and include gas flow measurement into the monitoring on the Park & Ride gas mains

o Calibrate the gas alarm system at Park & Ride

o Consider burying the pipework and protecting the wellheads with concrete

rings to prevent unauthorised access at the Blue Demons area

o Continue monitoring, regular reviews of risk assessment / gas control strategy at the Blue Demons area and report to the Agency.

o Continue monitoring, regular reviews of risk assessment and report to the

Agency any potential issues identified at the Greenhills area.

o While taking gas well readings mark in comments on gas records sheets:

- valve position - low diameter bypass connection

o Keep the records of changes documented and updated.



APPENDIX 1 Operating and monitoring data Due to the volume of the data the collated and systematised, information is contained in the excel files attached to this report, separated for monitoring boreholes and gas wells for years 2016 and 2017. For visualisation of the gas parameters for individual wells and boreholes linear graphs are automatically generated within the spreadsheet after selection of a particular gas well or monitoring borehole. This Appendix presents only the statistics and the outcome of the data interpretation. In order to maintain consistency and enable comparison of the audit results, the “Traffic light – Red-Amber-Green [RAG]” allocations (assessment and interpretation) were based on the following criteria used in the last audit. Combination of the parameters and their ranges, as listed in the Table 15, is used for the gas wells. Table 15 RAG criteria for gas wells assessment

Green gas wells are characterised by combination of stable or improving performance with high methane content, low oxygen and nitrogen (balance gas) concentrations, CH4/CO2 ratio falling within the stable methanogenesis range and relatively low suction. Long term (yearly) trends of gas quality and suction are evaluated during the well classification.

Amber gas wells have slightly worse gas quality, but maintained above 40% CH4, below 3% O2, less than 30% nitrogen (balance gas), relatively higher suction and more fluctuations in trends. CH4/CO2 ratio falls outside the optimum for stable methanogenesis.

Red gas wells have rather poor quality gas (less than 40% CH4, more than 3% O2 and/or more than 30% nitrogen (balance gas). They behaviour is erratic and they may not show easily defined trends.

Combination of the parameters mentioned in the Table 15 is arbitrary and evaluation is based on experience of similar assessments in the past, carried out on numerous landfills. Such methodology enables quick and consistent comparison of performance of gas wells and gas collection systems as a whole.

The more “green” wells and the less “red” wells, the better the performance of the gas control system.

trend 1 trend 2 trend 3 CH4 %vv O2 %vv N2 %vv SP mbar CH4/CO2 mark

increasing stable improvement <40 >3 >30 >10 <1.3, >1.7 red

decreasing unstable worsening 40‐50 1 ‐ 3 10 ‐ 30 5 ‐ 10 <1.3, >1.7 amber

undefined undefined undefined >50 <1 <10 <5 1.3 ‐ 1.7 green



Table 16 Gas wells - 2016 RAG classification by phase

Table 17 Gas wells - 2017 RAG classification by phase

Comparison of the statistics in years 2015-2017 shows: - significant improvement trend on Phases 1,2 and 3 (P1 – increase from 13 to 39% green; decline from 56 to 39% red), (P2 – increase from 24 to 57% green; decline from 29 to 26% red), (P3 – increase from from 11 to 20% green; decline from 63 to 45% red) and - indication of slight declining trend on Phase 4 (decline from 29 to 25% green). Phase 4 is the most complicated to balance due to the number of gas wells and interactions between them. Phase 5 was not included in the comparison as more data is needed to make conclusions.

2016phase 1 phase 2 phase 3 phase 4 total No total %

4 8 2 27 41 23%

10 16 5 30 61 34%

18 10 12 36 76 43%

total 32 34 19 93 178

phase 1 phase 2 phase 3 phase 4

13% 24% 11% 29%

31% 47% 26% 32%

56% 29% 63% 39%

total 100% 100% 100% 100%

2017phase 1 phase 2 phase 3 phase 4 total No total %

13 20 4 23 60 33%

7 6 7 33 53 29%

13 9 9 36 67 37%

total 33 35 20 92 180

phase 1 phase 2 phase 3 phase 4

39% 57% 20% 25%

21% 17% 35% 36%

39% 26% 45% 39%

total 100% 100% 100% 100%



Table 18 Comparison of gas well RAG classification 2015 – 2017 by phase (numeric)

Performance of each phase can be easily seen from the Table 18 above:

- Improvement on Phases 1 and 2 - Slight improvement on phase 3 - More or less steady state on Phase 4.

The same numbers can be also presented in percent (Table 19)

2015 phase 1 2016 phase 1 2017 phase 1

GREEN 0 4 13

AMBER 10 10 7

RED 21 18 13

TOTAL 31 32 33


GREEN 7 8 20

AMBER 17 16 6

RED 10 10 9

TOTAL 34 34 35


GREEN 3 2 4

AMBER 8 5 7

RED 9 12 9

TOTAL 20 19 20


GREEN 22 27 23

AMBER 31 30 33

RED 40 36 36

TOTAL 93 93 92



Table 19 Comparison of gas well RAG classification 2015 – 2017 by phase (percent)


GREEN 0% 13% 39%

AMBER 32% 31% 21%

RED 68% 56% 39%

TOTAL 100% 100% 100%


GREEN 21% 24% 57%

AMBER 50% 47% 17%

RED 29% 29% 26%

TOTAL 100% 100% 100%


GREEN 15% 11% 20%

AMBER 40% 26% 35%

RED 45% 63% 45%

TOTAL 100% 100% 100%


GREEN 24% 29% 25%

AMBER 33% 32% 36%

RED 43% 39% 39%

TOTAL 100% 100% 100%



The evaluation criteria for gas monitoring boreholes are presented in Table 20. These are different in comparison to the gas wells, and based mainly on combination of concentrations of measured gases, trends of methane and carbon dioxide and percent transgressions per year above values prescribed by the licence.

Table 20 RAG classification criteria for gas monitoring boreholes

Monitoring boreholes statistics: Table 21 Gas monitoring boreholes – RAG classification 2016

Trend Transgressions CH4 % vv CO2 % vv mark

increasing none >5 >10 red

decreasing <10% <5 <10 amber

undefined >10% <1 <1.5 green

stable

2016CH4Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

3 24 3 3 13 46 85%

0 0 0 0 0 0 0%

3 1 0 0 4 8 15%

total 6 25 3 3 17 54

Blue Demons Greenhills Landfill North Landfill South Park & Ride

50% 96% 100% 100% 76%

0% 0% 0% 0% 0%

50% 4% 0% 0% 24%

total 100% 100% 100% 100% 100%

CO2Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

0 4 0 1 8 13 24%

3 19 3 2 8 35 65%

3 2 0 0 1 6 11%

total 6 25 3 3 17 54


0% 16% 0% 33% 47%

50% 76% 100% 67% 47%

50% 8% 0% 0% 6%

total 100% 100% 100% 100% 100%

CH4 + CO2Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

0 20 2 2 13 37 69%

3 4 1 1 0 9 17%

3 1 0 0 4 8 15%

total 6 25 3 3 17 54


0% 80% 67% 67% 76%

50% 16% 33% 33% 0%

50% 4% 0% 0% 24%

total 100% 100% 100% 100% 100%



Table 22 Gas monitoring boreholes – RAG classification 2017

2017CH4Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

5 23 3 3 17 51 96%

0 0 0 0 0 0 0%

1 1 0 0 0 2 4%

total 6 24 3 3 17 53


83% 96% 100% 100% 100%

0% 0% 0% 0% 0%

17% 4% 0% 0% 0%

total 100% 100% 100% 100% 100%

CO2Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

0 5 0 1 8 14 26%

5 17 3 1 9 35 66%

1 2 0 1 0 4 8%

total 6 24 3 3 17 53


0% 21% 0% 33% 47%

83% 71% 100% 33% 53%

17% 8% 0% 33% 0%

total 100% 100% 100% 100% 100%

CH4 + CO2Blue Demons Greenhills Landfill North Landfill South Park & Ride total No total %

0 18 3 2 17 40 75%

5 5 0 1 0 11 21%

1 1 0 0 0 2 4%

total 6 24 3 3 17 53


0% 75% 100% 67% 100%

83% 21% 0% 33% 0%

17% 4% 0% 0% 0%

total 100% 100% 100% 100% 100%



Comparison of the statistics in years 2015-2017, utilising the same assessment criteria, shows the following trends with respect to gas monitoring: Table 23 Trends on gas monitoring boreholes 2015 - 2017

Area CH4 CO2 CH4 & CO2

Blue Demons Improvement Improvement Improvement

Greenhills No Change Improvement Slight Decline

Landfill North No Change No Change No Change

Landfill South No Change Slight Decline No Change

Park & Ride Improvement Slight Decline Improvement

The supporting evidence for these conclusions can be found in the summary tables 24 – 29 below. Table 24 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4, numeric)

CH4

Blue Demons 2015 2016 2017

GREEN 2 3 5

AMBER 1 0 0

RED 3 3 1

TOTAL 6 6 6

CH4

Greenhills 2015 2016 2017

GREEN 24 24 23

AMBER 0 0 0

RED 1 1 1

TOTAL 25 25 24

CH4

Landfill North 2015 2016 2017

GREEN 3 3 3

AMBER 0 0 0

RED 0 0 0

TOTAL 3 3 3

CH4

Landfill South 2015 2016 2017

GREEN 3 3 3

AMBER 0 0 0

RED 0 0 0

TOTAL 3 3 3

CH4

Park & Ride 2015 2016 2017

GREEN 14 13 17

AMBER 2 0 0

RED 1 4 0

TOTAL 17 17 17



Table 25 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4, percent)

CH4

Blue Demons 2015 2016 2017

GREEN 33% 50% 83%

AMBER 17% 0% 0%

RED 50% 50% 17%

TOTAL 100% 100% 100%

CH4


GREEN 96% 96% 96%

AMBER 0% 0% 0%

RED 4% 4% 4%

TOTAL 100% 100% 100%

CH4


GREEN 100% 100% 100%

AMBER 0% 0% 0%

RED 0% 0% 0%

TOTAL 100% 100% 100%

CH4


GREEN 100% 100% 100%

AMBER 0% 0% 0%

RED 0% 0% 0%

TOTAL 100% 100% 100%

CH4

Park & Ride 2015 2016 2017

GREEN 82% 76% 100%

AMBER 12% 0% 0%

RED 6% 24% 0%

TOTAL 100% 100% 100%



Table 26 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CO2, numeric)

CO2

Blue Demons 2015 2016 2017

GREEN 0 0 0

AMBER 1 3 5

RED 5 3 1

TOTAL 6 6 6

CO2


GREEN 3 4 5

AMBER 19 19 17

RED 3 2 2

TOTAL 25 25 24

CO2


GREEN 0 0 0

AMBER 3 3 3

RED 0 0 0

TOTAL 3 3 3

CO2


GREEN 1 1 1

AMBER 2 2 1

RED 0 0 1

TOTAL 3 3 3

CO2

Park & Ride 2015 2016 2017

GREEN 9 8 8

AMBER 8 8 9

RED 0 1 0

TOTAL 17 17 17



Table 27 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CO2, percent)

CO2

Blue Demons 2015 2016 2017

GREEN 0% 0% 0%

AMBER 17% 50% 83%

RED 83% 50% 17%

TOTAL 100% 100% 100%

CO2


GREEN 12% 16% 21%

AMBER 76% 76% 71%

RED 12% 8% 8%

TOTAL 100% 100% 100%

CO2


GREEN 0% 0% 0%

AMBER 100% 100% 100%

RED 0% 0% 0%

TOTAL 100% 100% 100%

CO2


GREEN 33% 33% 33%

AMBER 67% 67% 33%

RED 0% 0% 33%

TOTAL 100% 100% 100%

CO2

Park & Ride 2015 2016 2017

GREEN 53% 47% 47%

AMBER 47% 47% 53%

RED 0% 6% 0%

TOTAL 100% 100% 100%



Table 28 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4 & CO2, numeric)

CH4 & CO2

Blue Demons 2015 2016 2017

GREEN 0 0 0

AMBER 2 3 5

RED 4 3 1

TOTAL 6 6 6

CH4 & CO2


GREEN 20 20 18

AMBER 4 4 5

RED 1 1 1

TOTAL 25 25 24

CH4 & CO2


GREEN 3 2 3

AMBER 0 1 0

RED 0 0 0

TOTAL 3 3 3

CH4 & CO2


GREEN 2 2 2

AMBER 1 1 1

RED 0 0 0

TOTAL 3 3 3

CH4 & CO2

Park & Ride 2015 2016 2017

GREEN 14 13 17

AMBER 3 0 0

RED 0 4 0

TOTAL 17 17 17



Table 29 Comparison of gas monitoring boreholes RAG classification 2015 – 2017 (CH4 & CO2, percent)

Blue Demons – improvement, as orange boreholes increased from 33 to 83% and red fell from 67% to 17%. Greenhills – slight decline, as green boreholes fell from 80 to 75%, but orange increased from 16 to 21% at red at steady state of 4%. Landfill North and South – stable condition, with no significant changes over these three years. Park & Ride – improvement, as green boreholes increased from 82 to 100%.

CH4 & CO2

Blue Demons 2015 2016 2017

GREEN 0% 0% 0%

AMBER 33% 50% 83%

RED 67% 50% 17%

TOTAL 100% 100% 100%

CH4 & CO2


GREEN 80% 80% 75%

AMBER 16% 16% 21%

RED 4% 4% 4%

TOTAL 100% 100% 100%

CH4 & CO2


GREEN 100% 67% 100%

AMBER 0% 33% 0%

RED 0% 0% 0%

TOTAL 100% 100% 100%

CH4 & CO2


GREEN 67% 67% 67%

AMBER 33% 33% 33%

RED 0% 0% 0%

TOTAL 100% 100% 100%

CH4 & CO2

Park & Ride 2015 2016 2017

GREEN 82% 76% 100%

AMBER 18% 0% 0%

RED 0% 24% 0%

TOTAL 100% 100% 100%



Figure 1 Gas Monitoring Borehole RAG classification 2016 – Blue Demons

Please note – Blue Demons site is under active gas extraction (since 2015)



Figure 2 Gas Monitoring Borehole RAG classification 2016 - Greenhills



Figure 3 Gas Monitoring Borehole RAG classification 2016 – Landfill Perimeter



Figure 4 Gas Monitoring Borehole RAG classification 2016 – Park & Ride



Figure 5 Gas Monitoring Borehole RAG classification 2017 – Blue Demons

Please note – Blue Demons site is under active gas extraction (since 2015)



Figure 6 Gas Monitoring Borehole RAG classification 2017 – Greenhills



Figure 7 Gas Monitoring Borehole RAG classification 2017 – Landfill Perimeter



Figure 8 Gas Monitoring Borehole RAG classification 2017 – Park & Ride



APPENDIX 2 Landfill Gas Production Forecast (Gas Model)

A proprietary gas model, based on first order of decay and the IPPC methodology has been used to forecast gas production. Any landfill (biogas) gas generation modelling is a process that simplifies uncontrolled and complicated biochemical processes taking place in a landfill body. Any modelling has its own inherent errors and inaccuracies, caused by flaws in the data and the theoretical assumptions used, like formulae, half-life periods of decay, degradable carbon content, gas collection efficiency, etc. Therefore it is justified to show the landfill gas production prognosis as a range between an “optimistic” and “conservative” curves. The optimistic curve is used to design the gas collection system and the conservative one applies when selecting power generation equipment.

Figure 9 Landfill gas production forecast (phases 1-4) and current gas flow rate

The falling gas production trend is as expected.

Volume of collected gas is approaching the conservative curve and slightly below it, within the error margins of the model and gas flow rate measurements.

Optimisation of the gas field performance is a long term process and it needs careful approach. If there is no immediate need for gas migration, surface emissions or odour control, compromising gas quality may lead to adverse effects of dragging the atmospheric air into the waste body, turning the decomposition processes back to aerobic and in worst cases to subsurface fires.

Situation at Kinsale Road Landfill can be deemed under control, as neither odour not VOC emissions incidents have been reported, and the gas migration is well managed. These are the most important indicators of management of the gas generated on site. It is important to note

0

200

400

600

800

1000

1200

1400

1600

1980 1990 2000 2010 2020 2030 2040

GAS FLOW RAT

E [m

3 h‐1]

YEAR

KINSALE ROAD ‐ LANDFILL GAS PRODUCTION FORECAST (PHASES 1‐4)

Conservative Optimistic Gas flow rate 2017 Gas flow rate 2018



that collecting the gas from a relatively big and closed site, characterised with scattered microsources of gas, with oversized gas collection system is not an easy task, requiring experience and a high level of knowledge.

Figure 10 Landfill gas production forecast (historical phases i.e. P&R and Phase 5)

If converted to 50% methane concentration, old phases would generate less than 10 m3h-1 of landfill gas. Volume of the gas collected from these phases (over 500 m3h-1) is significantly higher from the predicted amount. This is caused by the need to maintain migration control on the areas adjacent to Phases 1-5.

0

50

100

150

200

250

300

350

1960 1970 1980 1990 2000 2010 2020 2030

GAS FLOW RATE

[m3 h‐1]

YEAR

KINSALE ROAD ‐ LANDFILL GAS PRODUCTION FORECAST (HISTORICAL PHASES ‐ CONSOLIDATED)

Total Old Conservative @ 50% Total Old Optimistic @ 50%

2018



APPENDIX 3 Comparison of manual and continuous gas monitoring data

The site personnel reported poor data feed from the AmbiSense Units in recent period of time, hence more frequent reviews of the logged data is suggested in order to verify the peaks recorded by the continuous gas analyser units with portable gas analyser. The site personnel reported annual calibration of the units; however, no certificates were received from the supplier. As soon as the data is verified, the justification of the continuous gas monitoring should be reviewed at selected locations.

Figure 11 Comparison of manual and continuous readings (methane – borehole 137)

Figure 12 Comparison of manual and continuous readings (carbon dioxide – borehole 137)

0

10

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30

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60

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90

100

0

0.1

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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17

PARK & RIDE ‐ COMPARISON OF MANUAL AND CONTINUOUS READINGS ‐ 137

CH4 % vol. CH4 Ambi avg % vv

0

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0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

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5.0

26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17


CO2 % vol. CO2 Ambi avg % vv





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100

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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17



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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17







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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17





Figure 21 Comparison of manual and continuous readings (methane – borehole LG12)

Figure 22 Comparison of manual and continuous readings (carbon dioxide – borehole LG12)

0

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100

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0.2

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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17

PARK & RIDE ‐ COMPARISON OF MANUAL AND CONTINUOUS READINGS ‐ LG12


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0.5

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1.5

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3.5

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26‐12‐16 14‐02‐17 05‐04‐17 25‐05‐17 14‐07‐17 02‐09‐17 22‐10‐17 11‐12‐17

PARK & RIDE ‐ COMPARISON OF MANUAL AND CONTINUOUS READINGS ‐ LG12




APPENDIX 4 Gas well dipping results

Table 30 Gas well dipping results – January 2018

Out of 94 gas wells, only 31 were accessible for dipping

Date Phase Well Temp oC depth to liquid m well depth m comments 1

31‐01‐18 Phase 4 P4GW 1 18 6 10.831‐01‐18 Phase 4 P4GW2 24 8.2 12.831‐01‐18 Phase 4 P4GW6 21 11.5 13.831‐01‐18 Phase 4 P4GW7 32 14.1 15.231‐01‐18 Phase 4 P4GW8 23 9.9 10.631‐01‐18 Phase 4 P4GW9 23 9.9 12.131‐01‐18 Phase 4 P4GW13 28 10.5 20.531‐01‐18 Phase 4 P4GW16 23 13.5 17.831‐01‐18 Phase 4 P4GW21 3.2m Dry31‐01‐18 Phase 4 P4GW24 26 14.9 18.431‐01‐18 Phase 4 P4GW26 12 17.7m Dry31‐01‐18 Phase 4 P4GW28 10 4.2m Dry31‐01‐18 Phase 4 P4GW31 22 8.3 12.231‐01‐18 Phase 4 P4GW39 20 11.5 13.631‐01‐18 Phase 4 P4GW44 10 8.0m Dry31‐01‐18 Phase 4 P4GW45 27 14.1 1531‐01‐18 Phase 4 P4GW49 17 12.6 12.831‐01‐18 Phase 4 P4GW52 22 13.6 1631‐01‐18 Phase 4 P4GW53 23 15.04 19.831‐01‐18 Phase 4 P4GW54 23 8 17.831‐01‐18 Phase 4 P4GW56 24 14.9 15.631‐01‐18 Phase 4 P4GW57 26 13.1 1531‐01‐18 Phase 4 P4GW63 20 10.3 15.731‐01‐18 Phase 4 P4GW67 10 Dry 6.6 Dry31‐01‐18 Phase 4 P4GW71 10 Dry 1.9 Dry31‐01‐18 Phase 4 P4GW72 9 1.4 1.431‐01‐18 Phase 4 P4GW76 16 Dry 11.1 Dry31‐01‐18 Phase 4 P4GW86 17 Dry 6.9 Dry31‐01‐18 Phase 4 P4GW87 9 Dry 7.9 Dry31‐01‐18 Phase 4 P4GW90 9 Dry 7.4 Dry31‐01‐18 Phase 4 P4GW93 24 0.1 6.6



Figure 23 Well dipping results – January 2018

Well dipping indicates that majority of the checked wells have a perforated section open to the gas flow. The leachate levels are not significantly hindering their functionality concerning the gas collection (indicating the deep borehole wells are functioning as intended in maintaining a low leachate head within the waste body).

Figure 24 Gas well temperature – January 2018

The temperatures in all the wells, bar P4GW7, are below optimum for mesophilic methanogenesis. This indicates relatively slow gas generation in Phase 4 and corresponds with the gas flow rate seen at the gas flare and generator compound.

‐25

‐20

‐15

‐10

‐5

0

WELL DIPPING ‐ PHASE 4

WD m ppt LL m ppt

0

5

10

15

20

25

30

35

40

45

50

TEMPERATURE [oC] IN ACCESSIBLE GAS WELLS ‐ PHASE 4



APPENDIX 5 Comparison of the PRTR data

Table 31 Comparison of the PRTR data 2014 - 2017

The data indicate that emissions from the site are well below limits stipulated for landfills.

Source

Carbon

Monoxide

(CO) kg/yr

Carbon

Dioxide (CO2)

kg/yr

Nitrogen

Oxides

(NOx as

NO2) kg/yr

TNM VOC's

kg/yr

Sulphur

Dioxide

(SO2) kg/yr

Total

particulates

kg/yr

Methane

kg/yr

2017 Flare 77 845,713 751 ‐ 433 ‐ 22

2016 Flare 11 924,002 438 ‐ 105 ‐ 20

2015 Flare 39 917,527 562 ‐ 122 ‐ 25

2014 Flare 76 991,341 297 ‐ 25 ‐ 29

2017 Engine 19,342 3,632,462 6,833 13 3,573 36 ‐

2016 Engine 10,108 3,121,204 7,102 10 6,081 37 ‐

2015 Engine 10,231 2,692,918 3,798 23 5,456 170 9,569

2014 Engine

2017 Engine & Flare 19,419 4,478,175 7,584 13 4,006 36 22

2016 Engine & Flare 10,119 4,045,206 7,540 10 6,186 37 20

2015 Engine & Flare 10,270 3,610,445 4,360 23 5,578 170 9,594

2016 Flare 76 991,341 297 ‐ 25 ‐ 29

Compliance limit 500,000 100,000,000 100,000 100,000 150,000 50,000 100,000



APPENDIX 6 Power Station Performance 2015 - 2017

Table 32 Landfill gas power station performance 2015 - 2018

Power generation is on steady, slightly falling trend, in accordance with the expected gas generation on site.

DATEPOWER GENERATED

[kWh/month]

CUMULATIVE POWER

GENERATED [kWh]

30‐11‐15 84,700 84,700

21‐12‐15 166,800 251,500

07‐01‐16 279,300 530,800

29‐01‐16 201,200 732,000

01‐02‐16 282,400 1,014,400

01‐03‐16 270,200 1,284,600

06‐04‐16 277,900 1,562,500

06‐05‐16 238,700 1,801,200

02‐06‐16 226,500 2,027,700

11‐07‐16 193,090 2,220,790

08‐08‐16 302,100 2,522,890

05‐09‐16 295,600 2,818,490

05‐10‐16 296,800 3,115,290

02‐11‐16 294,000 3,409,290

06‐12‐16 282,700 3,691,990

04‐01‐17 256,800 3,948,790

13‐02‐17 269,900 4,218,690

13‐03‐17 188,300 4,406,990

20‐04‐17 226,200 4,633,190

04‐05‐17 211,300 4,844,490

13‐06‐17 224,100 5,068,590

07‐07‐17 231,400 5,299,990

01‐08‐17 209,500 5,509,490

11‐09‐17 239,700 5,749,190

06‐10‐17 227,500 5,976,690

13‐11‐17 238,700 6,215,390

11‐12‐17 209,900 6,425,290

08‐01‐18 193,100 6,618,390

05‐02‐18 176,300 6,794,690



Figure 25 Power station performance 2015-2018 – monthly power generation

Figure 26 Power station performance 2015-2018 – cumulative power generation

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

30‐11‐15

31‐12‐15

31‐01‐16

29‐02‐16

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DATE

POWER GENERATED [kWh/month]

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DATE

CUMULATIVE POWER GENERATED [kWh]

ANNUAL SITE AUDIT LANDFILL GAS CONTROL SYSTEM 2016 – … · 2019. 1. 26. · Table 31 Comparison...

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