NSPS MACT Report

Environmental Consultants 11260 Roger Bacon Drive 703 471-6150 Reston, VA 20190-5258 FAX 703 471-6676 www.scsengineers.com

Offices Nationwide

July 27, 2014 File No. 02204045.01 Mr. Dave Moreira Senior District Manager Waste Management Disposal Services of Pennsylvania, Inc. 4 Liberty Lane West Hampton, New Hampshire 30842 Subject: Report of NSPS and MACT Compliance

Pottstown Landfill and Recycling Center Dear Mr. Moreira: SCS Engineers (SCS) is pleased to submit the enclosed report documenting operation of the LFG collection and control system at the Pottstown Landfill and Recycling Center (Pottstown LRC) in accordance with the EPA’s NSPS and NESHAP requirements for landfills. This report covers the operational period of January through June 2014. One copy should be sent to both the PADEP and EPA Region III, postmarked by August 1:

Office of Air Enforcement and Compliance Assistance (3AP20) U.S. Environmental Protection Agency, Region III 1650 Arch Street Philadelphia, PA 19103-2029 Mr. James Rebarchak Regional Air Program Manager Pennsylvania Department of Environmental Protection, Southeast Region 2 East Main Street Norristown, Pennsylvania 19401

Please remember that the report Certification page must be completed prior to submittal. If you have any questions regarding this report, please do not hesitate to telephone me at 703-471-6150. Sincerely,

Joshua G. Roth, P.E. Project Manager SCS ENGINEERS

POTTSTOWN LANDF ILL AND RECYCL ING CENTER

Operational Report for New Source Performance Standards (NSPS) and National

Emission Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills

January through June 2014

Submitted by:

POTTSTOWN LANDFILL AND RECYCLING CENTER 1425 Sell Road

Pottstown, Pennsylvania 19464 (610) 327-2703

Submitted to:

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION Air Quality Program

Southeast Regional Office 2 East Main Street

Norristown, Pennsylvania 19401

Prepared by:

SCS ENGINEERS 11260 Roger Bacon Drive Suite 300

Reston, Virginia 20190 (703) 471-6150

July 2014 File No. 02204045.01

Offices Nationwide

www.scsengineers.com

Pot ts town Landf i l l and Recycl ing Center Operat ional Report

POTTSTOWN LANDFILL AND RECYCLING CENTER

OPERATIONAL REPORT FOR NEW SOURCE PERFORMANCE STANDARDS (NSPS) AND NATIONAL EMISSION STANDARDS

FOR HAZARDOUS AIR POLLUTANTS (NESHAP) FOR MUNICIPAL SOLID WASTE LANDFILLS

JANUARY THROUGH JUNE 2014

Submitted by:

POTTSTOWN LANDFILL AND RECYCLING CENTER 1425 Sell Road

Pottstown, Pennsylvania 19464 (610) 327-2703

Submitted to:

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION Air Quality Program

Southeast Regional Office 2 East Main Street

Norristown, Pennsylvania 19401

Prepared by:

SCS ENGINEERS 11260 Roger Bacon Drive Suite 300

Reston, Virginia 20190 (703) 471-6150

July 2014 File No. 02204045.01


i

T a b l e o f C o n t e n t s Section Page 1.0 Executive Summary ............................................................................................................................ 1-1 2.0 Landfill and Gas Collection System Description .......................................................................... 2-1

2.1 Landfill Background ................................................................................................................. 2-1 2.2 LFG Collection System ............................................................................................................. 2-1

2.2.1 Primary LFG Collection System ....................................................................... 2-1 2.2.2 Supplemental LFG Collection ........................................................................... 2-1

2.3 Control System .......................................................................................................................... 2-1 3.0 LFG Collection and Control System Operations .......................................................................... 3-1

3.1 Collection System Operation ................................................................................................. 3-1 3.1.1 Alternative Monitoring/Recordkeeping/Reporting Procedures ................ 3-1 3.1.2 Wellhead Monitoring Results ........................................................................... 3-1 3.1.3 System Downtime ............................................................................................... 3-3

3.2 Control Device Operation ...................................................................................................... 3-3 3.2.1 Gas Stream Diversion ....................................................................................... 3-4 3.2.2 Combustion Temperature .................................................................................. 3-4 3.2.3 Flow Monitoring .................................................................................................. 3-5

3.3 Methane Surface Emissions Monitoring ................................................................................ 3-5 3.4 New Wells or Collection System Expansion ........................................................................ 3-5 3.5 Well Decommissioning ............................................................................................................ 3-5

4.0 Startup, Shutdown And Malfunction (SSM) Events ....................................................................... 4-1 4.1 Startup, Shutdown and Malfunction Events ......................................................................... 4-1

4.1.1 GCCS Startup Events ......................................................................................... 4-1 4.1.2 GCCS Shutdown Events ..................................................................................... 4-1 4.1.3 GCCS Malfunction Events ................................................................................. 4-1

4.2 SSM Plan Revisions .................................................................................................................. 4-1 A p p e n d i c e s Appendix A – Summary of NSPS Monitoring Results, Operating Wells Appendix B – Summary of SEM Monitoring Results Appendix C – Report Certification


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1 .0 EXECUT IVE SUMMARY

This Report has been prepared for the Pottstown Landfill and Recycling Center (the landfill) in accordance with the New Source Performance Standards (NSPS) and the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Municipal Solid Waste Landfills.

Pottstown Landfill and Recycling Center prepared and submitted to the Pennsylvania Department of Environmental Protection (PADEP) a gas collection and control system (GCCS) Design Plan for the Landfill in June 1997. Updates to the GCCS Design Plan were submitted to PADEP in December 2002 and addressed the Eastern Expansion area. Pottstown Landfill has also submitted a number of requests for alternate operating scenarios and higher operating values at particular extraction points in accordance with the NSPS.

The GCCS Plan was developed in accordance with the requirements set forth in the NSPS and the landfill’s Title V Operating Permit (No. 46-00033), and provides for gas collection from those areas of the landfill “defined as active areas where the first refuse deposited in the area has reached an age of 5 years or more or areas closed or at final grade where the first refuse deposited in the areas has reached an age of 2 years or more”. In accordance with the GCCS Plan and the NSPS, the Pottstown Landfill installed and commenced operation of a GCCS for purposes of NSPS compliance.

This report provides information required by the NSPS and the NESHAP relative to operational parameters, including:

Wellhead operations, including vacuum requirements, oxygen or nitrogen limits, and maximum wellhead temperatures.

Control device and collection system operations, including information regarding system downtime or bypass status and combustion temperature monitoring.

Methane surface emission testing.

Startup, shutdown and malfunction reporting.


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2 .0 LANDF I L L AND GAS COLLECT ION SYSTEM DESCR IPT ION

2 . 1 L A N D F I L L B A C K G R O U N D

The Pottstown Landfill is a municipal solid waste landfill located in Pottstown, Pennsylvania, and West Pottsgrove Township and Montgomery County.

The landfill increased its permitted waste disposal volume after May 30, 1991, and has a design capacity greater than 2.5 million cubic meters. As such, the landfill is subject to the NSPS for MSW landfills. Additionally, the landfill is subject to the NESHAP requirements for MSW landfills, which became effective January 16, 2004.

The Pottstown Landfill ceased accepting MSW on September 30, 2005.

2 . 2 L F G C O L L E C T I O N S Y S T E M

2 . 2 . 1 P r i m a r y L F G C o l l e c t i o n S y s t e m

The primary means of LFG collection is via a comprehensive series of vertical extraction wells installed on both the Western Landfill area and the Eastern Expansion area. Connections between the extraction wells and the main gas header system are typically made using piping ranging in diameters from 6 to 24 inches.

Each well is equipped with a valve to control LFG flow, and vacuum and monitoring ports to measure LFG quality. A temperature probe is also placed on the well to measure LFG temperatures. Flexible piping connects the wellhead with the header and is intended to accommodate differential settlement near each well.

2 . 2 . 2 S u p p l e m e n t a l L F G C o l l e c t i o n

The landfill also performs supplemental LFG collection from other collection points such as leachate collection risers/cleanouts, as well as trench-head risers.

Gas collection from supplemental collection points is implemented as appropriate. These connections are intended to enhance the landfill’s overall gas collection and provide additional emissions/odor control as needed. These collection points were not necessarily engineered for gas collection and often have poor gas quality. While these features are not part of the GCCS and are not subject to the operational requirements of the NSPS (per PADEP approval), gas monitoring is conducted at these points as a general gas system management practice.

2 . 3 C O N T R O L S Y S T E M

The landfill installed three enclosed ground flaring stations for the control of LFG emissions, hereafter referred to as Flare No. 1, Flare No. 2 and Flare No. 3. Flares No. 1 and 2 were installed at the Western Landfill area and rated for approximately 2,800 cfm. Flare No. 3 is


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located at the Eastern Expansion area and rated for approximately 1,800 cfm. In November 2009, the landfill removed Flare 1 from the site.

The Flare 2 and Flare 3 stations include the following main equipment, at a minimum:

Enclosed ground flare designed to achieve a minimum 98 percent NMOC destruction efficiency or reduce outlet NMOC concentration to less than 20 ppmv as required by the NSPS.

Gas mover equipment, including gas blowers designed to apply a vacuum to the gas wellfield and deliver LFG to the flare.

Automatic control valve designed to immediately close of the flare shuts down in order to prevent uncombusted LFG from exhausting through the flare stack.

Gas pilot system.

Gas flow meter.

Thermocouple(s) to measure combustion temperature within the flare stack.

Data recorder.

The landfill also operates a landfill gas to energy (LFGTE) facility which consists of one LFG-fueled turbine for the production of electricity (one turbine [Turbine No. 1] was previously removed from the site and therefore will no longer operate). Gas is directed to the turbine via a gas compressor station. Prior to combustion, the LFG is filtered, compressed and dewatered in accordance with determinations made by the U.S. EPA regarding gas “treatment” as outlined in the NSPS. As such, the turbine is not subject to the monitoring or recordkeeping requirements of the NSPS.


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3 .0 L FG COLLECT ION AND CONTROL SYSTEM OPERAT IONS

3 . 1 C O L L E C T I O N S Y S T E M O P E R A T I O N

Each gas extraction point was monitored monthly for applicable NSPS parameters during the reporting period. The results of this monitoring are summarized below.

3 . 1 . 1 A l t e r n a t i v e M o n i t o r i n g / R e c o r d k e e p i n g / R e p o r t i n g P r o c e d u r e s

In accordance with the NSPS, the landfill submitted a number of requests for alternate operating scenarios and higher operating values at particular extraction points in accordance with the NSPS. The following is a summary of alternate operating scenarios which, to date, have been approved by the PADEP:

NSPS limits for oxygen, nitrogen and pressure are not applicable to gas extraction from leachate cleanout risers.

NSPS limits for oxygen, nitrogen, pressure and temperature are not applicable to gas extraction from trench head points.

Higher operating values (HOVs) for temperature at the following wells: GW 24 (145 ºF), GW 86D (145 ºF), GW 108 (145 ºF), GW 159 (145 ºF), GW 131D (145 ºF), GW 132D (145 ºF), GW 173D (145 ºF), EGW B (145 ºF), EGW 008 (146 ºF), EGW 009 (150 ºF), EGW 012 (148 ºF), EGW 013 (158 ºF), EGW 019 (150 ºF), EGW 024 (156 ºF), EGW 025 (148 ºF), EGW 030 (149 ºF), EGW 031 (145 ºF), EGW 035 (149 ºF), EGW 036 (148 ºF)

Extraction wells may be temporarily decommissioned from service due to declining gas production or gas quality. During this period, weekly wellhead monitoring is required, and monthly SEM monitoring around the well is required. Sufficient data must be gathered prior to requesting permanent decommissioning of an extraction well.

3 . 1 . 2 W e l l h e a d M o n i t o r i n g R e s u l t s

Wellhead Oxygen Concentration

The landfill conducts monthly (at a minimum) oxygen monitoring at individual wellheads for evaluation with respect to the NSPS default operational threshold of 5 percent. It is important to note that the NSPS expressly provides that a landfill may establish higher operating values for oxygen (or nitrogen), provided that operating data indicate that the elevated operating value does not cause fires or significantly inhibit anaerobic decomposition by inhibiting methanogens. During the reporting period, there were a limited number of instances where the oxygen level at an active gas collection point was measured to exceed the NSPS default level of 5 percent. In each case, appropriate remedial actions were initiated and the oxygen level was reduced to less


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than 5 percent within the default 15-day NSPS period. Therefore, the exceedances of the well operational oxygen pressure standards measured during the period are not deviations. Table A-1 included in Appendix A provides details regarding those instances where oxygen levels were measured to exceed the NSPS default operating threshold of 5 percent at operating wells, including the response actions which were initiated, follow-up readings, and other relevant information and details. Wellhead Pressure

The landfill’s operational objective is to generally maintain a negative pressure at each wellhead. However, it should be noted that per the NSPS a negative pressure is not required to be maintained under the following conditions:

A fire or increased well temperature. Use of a geomembrane or synthetic cover. A decommissioned well.

During the reporting period, there were a limited number of instances where the static pressure at an active gas collection point was measured to exceed the NSPS default level. In each case, appropriate remedial actions were initiated and vacuum was re-established at the well within the default 15-day NSPS period. Therefore, the exceedances of the well operational pressure standards measured during the period are not deviations.

Table A-2 included in Appendix A provides details regarding those instances where pressure levels were measured to exceed the NSPS default operating threshold, including the response actions which were initiated, follow-up readings, and other relevant information and details. Wellhead Temperature

During the reporting period, there were no instances where the temperature at an active GCCS gas collection point was measured to exceed the NSPS default level of 55oC (131oF) or an approved HOV level (see above), where applicable.

Temporarily Decommissioned Wells

No extraction wells were temporarily decommissioned during the reporting period. Leachate Collection Features

As noted previously, the landfill also performs LFG collection from a number of supplemental points such as leachate cleanout risers and trench head risers. While these features are not part of the GCCS and are not subject to the operational requirements of the NSPS (per PADEP approval), gas monitoring is conducted at these points as a general gas system management practice.

It should be noted that during the reporting period, temperatures measured at all active supplemental gas collection points were below 131 deg F during each monitoring event.


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3 . 1 . 3 S y s t e m D o w n t i m e

At no time during the reporting period was the collection system not operating for a period of more than 5 days.

3 . 2 C O N T R O L D E V I C E O P E R A T I O N

The NSPS requires a report of all periods during which a control device was not operating for more than one hour, and a report of the duration of each event. Pottstown LRC operates its control devices in parallel to control landfill gas emissions. The devices include Turbine #2 (Turbine #1 was removed from the site) and Flares #2 and #3 (Flare #1 was removed from the site). The landfill gas collection system operates only when one (or more) of these control devices is operational. During the reporting period, there were a limited number of instances where all control devices, the flare(s) and the LFGTE facility, were out of operation for a period exceeding 1 hour. In all of these instances, the landfill gas collection system ceased operation and the shutoff valve closed immediately in accordance with NSPS requirements. These instances are summarized as follows:

January 14. Both the LFGTE plant and the flares were shutdown for a period of approximately 2.8 hours following plant shutdown before the plant was re-started.



March 12. Both the LFGTE plant and the flares were shutdown for a period of approximately 2.8 hours following plant shutdown before the plant was re-started.

March 23. Both the LFGTE plant and the flares were shutdown for a period of approximately 39 hours following plant shutdown before the plant was re-started.

April 3. Both the LFGTE plant and the flares were shutdown for a period of approximately 1.9 hours following plant shutdown before Flare 2 was started.

April 3. Both the LFGTE plant and the flares were shutdown for a period of approximately 3 hours following shutdown of Flare 2 before the plant was re-started.

April 22. Both the LFGTE plant and the flares were shutdown for a period of approximately 1.5 hours following plant shutdown before the plant was re-started.

May 7. Both the LFGTE plant and the flares were shutdown for a period of approximately 1.2 hours following shutdown of Flare 2 before Flare 2 was restarted.


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May 7. Both the LFGTE plant and the flares were shutdown for a period of approximately 3.3 hours following shutdown of Flare 2 before the plant was re-started.

May 9. Both the LFGTE plant and the flares were shutdown for a period of approximately 1.5 hours following plant shutdown before the plant was re-started.



June 3. Both the LFGTE plant and the flares were shutdown for a period of approximately 4.8 hours following plant shutdown before the plant was re-started.

June 18. Both the LFGTE plant and the flares were shutdown for a period of approximately 8.5 hours following plant shutdown before the plant was re-started.

None of these events are considered to be Title V permit or NSPS deviations because in all instances the gas moving system was shutdown and all shutoff valves in the GCCS closed within 1 hour of each shutdown (in fact, immediately) to prevent venting of LFG to the atmosphere (see 40 CFR Section 60.753(e)). Furthermore, each of these events occurred during periods of startup, shutdown or malfunction (see Section 4). And, as noted previously, at no time was the collection system not operating for a period of more than 5 days.

3 . 2 . 1 G a s S t r e a m D i v e r s i o n

The Pottstown Landfill does not have a bypass line. Therefore, at no time during the reporting period was the LFG stream diverted from an LFG control or treatment device through a bypass line.

3 . 2 . 2 C o m b u s t i o n T e m p e r a t u r e

During the initial performance testing of Flare No. 2, an operating temperature of 1,500ºF was established; during the performance testing for Flare No. 3, an operating temperature of 1,600ºF was established. Additional performance testing of Flare No. 2 was conducted on October 26, 2006 at an average operating temperature of 1,575 ºF, and on October 5, 2011 at an average operating temperature of 1,546 ºF. Additional performance testing of Flare No. 3 was conducted on January 19, 2011 at an average operating temperature of 1,662ºF. These testing events confirm that NMOC emission control is in accordance with the NSPS requirements. During the reporting period, there were no instances during which the average operational combustion temperature of Flare No. 2 was measured to be more than 28ºC (50ºF) below the


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average combustion temperature measured for the enclosed flare during the performance test for a 3-hour block average period. Flare No. 3 did not operate during the period. 3 . 2 . 3 F l o w M o n i t o r i n g

During the reporting period, there were no instances where LFG flow was not measured and recorded during flare operation as required.

3 . 3 M E T H A N E S U R F A C E E M I S S I O N S M O N I T O R I N G

During the reporting period, two rounds of quarterly methane surface emissions monitoring (SEM) were conducted, in March and April/May 2014

During the SEM monitoring event conducted in March, methane in excess of the 500 ppm (above background emission levels) limit was detected at only one location. Appropriate remedial activities were performed, and 10-day and 30-day follow-up testing showed methane levels below the 500 ppm emissions limit. During the SEM monitoring event conducted April 29 through May 2, no exceedances of the 500 ppm (above background emission levels) limit were detected. Appendix B provides a summary of the initial and follow-up monitoring data related to SEM exceedances. In accordance with NSPS guidelines, including 40 CFR 60.755(c)(4)(iv) and 60.753(g), because the SEM exceedance was remediated appropriately and follow-up testing showed methane levels within the NSPS thresholds, no additional actions are required and this exceedance is not considered a deviation.

3 . 4 N E W W E L L S O R C O L L E C T I O N S Y S T E M E X P A N S I O N

During the reporting period, no new wells were installed nor were any collection system expansions made to the existing system in areas subject to the NSPS requirements.

3 . 5 W E L L D E C O M M I S S I O N I N G

No wells were permanently decommissioned from the GCCS during the reporting period.


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4 .0 STARTUP, SHUTDOWN AND MALFUNCT ION (SSM) EVENTS

The National Emission Standards for Hazardous Air Pollutants (NESHAP) Maximum Achievable Control Technology (MACT) Rule for Landfills became effective on January 16, 2003; compliance with the MACT began on January 16, 2004. In accordance with the MACT, the landfill developed and implemented an SSM Plan for the NSPS-compliant Gas Collection and Control System (GCCS). The NESHAP MACT regulations (40 CFR 63 Subpart AAAA) were amended in April 2006 (see 71 Federal Register 20446) to limit regular six-month reporting requirements to those startup and shutdown events where the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards, and malfunction events (including actions taken to correct a malfunction).

4 . 1 S T A R T U P , S H U T D O W N A N D M A L F U N C T I O N E V E N T S

4 . 1 . 1 G C C S S t a r t u p E v e n t s

During the reporting period, there were no startup events that that caused the source to exceed an applicable emission limitation.

4 . 1 . 2 G C C S S h u t d o w n E v e n t s

During the reporting period, there were no shutdown events that that caused the source to exceed an applicable emission limitation.

4 . 1 . 3 G C C S M a l f u n c t i o n E v e n t s

No GCCS malfunction events occurred during the reporting period.

4 . 2 S S M P L A N R E V I S I O N S

The actions taken in response to each SSM event during the reporting period were in accordance with the landfill’s SSM Plan. Therefore, no revisions to the plan were required during the reporting period.

A copy of the SSM Plan and all revisions or addenda are maintained at the landfill and are available to PADEP and EPA personnel for review if requested.


APPENDIX A

Summary of NSPS Monitoring Results Operating Wells

Table A-1: Pottstown Landfill and Recycling Center Summary of Wellhead Oxygen Measurements Exceeding Oxygen Limits


A-1-1

Well ID Month

O2 Level (%)

Temp (ºF)

Remedial Action/ Adjustment

Follow Up O2 Level

(%) Comments

EGW 001

January 8.7 34 Wellhead Adjusted 4.9 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 6 days after initial exceedance).

March 20.4 37 Wellhead Adjusted 3.9 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).

April 18.5 67 Wellhead Adjusted 0.7 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).

EGW 006 March 14.2 17 Wellhead Adjusted 1.7 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 13 days after initial exceedance).

EGW 007

January 14.4 66 Wellhead Adjusted 4.4 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 13 days after initial exceedance).

February 15.1 52 Wellhead Adjusted 4.9 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 14 days after initial exceedance).

March 14.8 33 Wellhead Adjusted 4.8 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).



A-1-2

Well ID Month

O2 Level (%)

Temp (ºF)


Follow Up O2 Level

(%) Comments

EGW 012


April 16.3 70 Wellhead Adjusted 0.0 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 4 days after initial exceedance).

May 15.5 76 Wellhead Adjusted 0.2 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 4 days after initial exceedance).

June 11.5 82 Wellhead Adjusted 4.7 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 6 days after initial exceedance).


EGW 023 March 6.2 21 Wellhead Adjusted 4.6 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).


GW 72 June 20.3 82 Wellhead Adjusted 0.0 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 8 days after initial exceedance).



A-1-3

Well ID Month

O2 Level (%)

Temp (ºF)


Follow Up O2 Level

(%) Comments

GW 78


March 9.0 70 Wellhead Adjusted 3.5 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 8 days after initial exceedance).


GW 80 April 12.9 49 Wellhead Adjusted 0.1 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).

GW 138

January 21.3 37 Wellhead Adjusted 4.6 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified same day as initial exceedance).


GW 56A





A-1-4

Well ID Month

O2 Level (%)

Temp (ºF)


Follow Up O2 Level

(%) Comments

GW 86D



GW 95R April 19.9 72 Wellhead Adjusted 1.2 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 7 days after initial exceedance).

GW 144D April 7.0 117 Wellhead Adjusted 1.2 No further action needed. Remedial action was effective in correcting the exceedance within 15 days (verified 1 day after initial exceedance).

Table A-2: Pottstown Landfill and Recycling Center Summary of Wellhead Pressure Measurements Exceeding Default NSPS Values


A-2-1

Well ID Month

Pressure Measured (in. w.c.) Remedial Action/Adjustment

Follow-up Pressure

Measured (in. w.c.) Comments

EGW 002 June 0.4 Increased applied vacuum at the wellhead -0.2 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

EGW 012

January 0.0 Increased applied vacuum at the wellhead -0.3 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

March 0.0 Increased applied vacuum at the wellhead -0.3 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

EGW 13 March 1.9 Increased applied vacuum at the wellhead -6.0 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

EGW 23


June 7.2 Increased applied vacuum at the wellhead -0.6 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

EGW 28 February 0.2 Increased applied vacuum at the wellhead -1.6 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).



A-2-2

Well ID Month


Follow-up Pressure








EGW 46 January 0.0 Increased applied vacuum at the wellhead -0.5 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).



A-2-3

Well ID Month


Follow-up Pressure


EGW ET1

March 3.1 Increased applied vacuum at the wellhead -4.6 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

June 3.7 Increased applied vacuum at the wellhead -1.0 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

EGW O26 February 2.3 Increased applied vacuum at the wellhead -0.2 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 15 April 0.1 Increased applied vacuum at the wellhead -4.5 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 21 January 0.2 Increased applied vacuum at the wellhead -0.8 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 22 February 0.1 Increased applied vacuum at the wellhead -0.4 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 36 April 0.1 Increased applied vacuum at the wellhead -0.4 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).



A-2-4

Well ID Month


Follow-up Pressure



GW 56 January 0.8 Increased applied vacuum at the wellhead -2.5 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).




GW 154


April 1.2 Increased applied vacuum at the wellhead -0.2 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).



A-2-5

Well ID Month


Follow-up Pressure


GW 33S January 0.0 Increased applied vacuum at the wellhead -0.8 No further action needed. Vacuum re-established within 15-day period (verified 12 days after initial exceedance).

GW 63R February 1.5 Increased applied vacuum at the wellhead -0.5 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 122D

February 0.6 Increased applied vacuum at the wellhead -1.8 No further action needed. Vacuum re-established within 15-day period (verified 13 days after initial exceedance).

April 1.7 Increased applied vacuum at the wellhead -2.3 No further action needed. Vacuum re-established within 15-day period (verified 9 days after initial exceedance).

GW 126S May 1.2 Increased applied vacuum at the wellhead -8.1 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 132D January 1.0 Increased applied vacuum at the wellhead -0.6 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).

GW 144D April 0.5 Increased applied vacuum at the wellhead -6.9 No further action needed. Vacuum re-established within 15-day period (verified 9 days after initial exceedance).



A-2-6

Well ID Month


Follow-up Pressure


GW 180D April 2.3 Increased applied vacuum at the wellhead -0.2 No further action needed. Vacuum re-established within 15-day period (verified same day as initial exceedance).


APPENDIX B

Summary of SEM Monitoring Results

Table B-1: Pottstown Landfill and Recycling Center – Surface Emissions Monitoring (SEM) Summary January through June 2014

B-1

Month Location Methane

Conc. (ppm) Remedial Action 10-Day Recheck

(ppm)

30-Day Recheck (ppm)

March 2014 Near leachate cleanout CO-20 9,947 GCCS vacuum adjustment 319 0


APPENDIX C

Report Certification

NSPS MACT Report

Documents

Transcript of NSPS MACT Report