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News Release RI Department of Environmental Management 235 Promenade Street, Providence, RI 02908 (401) 222-2771 TDD/(401) 222-4462
DEM ISSUES NOTICE OF VIOLATION TO RI RESOURCE RECOVERY CORPORATION AND BROADROCK GAS SERVICES LLC RRC owns and operates the Central Landfill on Shun Pike in Johnston and owns the landfill gas collection system. BroadRock Gas Services LLC installs, maintains and operates the landfill gas collection system. According to the NOV, DEM inspectors detected objectionable odors beyond the property line of the Central Landfill on seven occasions between October 12, 2011 and December 19, 2011, which are a violation of Air Pollution Control Regulation 17.2. The objectionable odor standard is the legal threshold that constitutes a violation of State regulations. Other odors, which did not meet this legal threshold, were detected on many other inspections. The RRC's air pollution control permit also requires RRC to notify DEM of any breakdown or malfunction of the remote gas flare used to burn off landfill gas within one hour of such an outage. This device became inoperable on November 23 and likely contributed to objectionable odors detected beyond the property line of the facility; RRC failed to notify DEM of the outage until five days later, on November 28. "Today's enforcement action is necessary because both RRC and BroadRock failed to maintain the landfill and the landfill gas collection and treatment systems to prevent the generation of unacceptable and objectionable odors beyond the facility boundaries; these odors have plagued the residents of Johnston and surrounding communities since last fall," said DEM Director Janet Coit. "Over the course of the past several months, DEM has conducted multiple inspections at the facility and off-site. We have also been closely monitoring the implementation of the corrective action plans by both RRC and BroadRock to resolve the odor problem. This notice requires that the additional steps recommended by environmental professionals and experts who have evaluated this situation be taken to ensure that the landfill gases are captured and not released into the atmosphere." Under the terms of the NOV and Order, the Respondents are required to immediately suspend further use of construction and demolition debris as cover material on the landfill. Construction and demolition debris contains sulfur, which contributes to the generation of the odorous hydrogen sulfide gas. DEM has included this provision in the NOV and Order to formalize cessation of this practice which RRC has already done on a voluntary basis. Also, within 30 days of the receipt of the NOV, RRC and BroadRock must submit a plan and schedule to implement numerous recommendations made by SCS Engineers, an independent consulting firm hired by RRC to review the landfill gas collection system, in its December 2011 report entitled "Landfill Gas Collection System Evaluation, RRC Landfill." In addition, the Respondents must submit a plan and schedule to implement SCS Engineers' recommendations related to the facility's landfill gas header system within 30 days of receipt of the NOV. Those recommendations were outlined in a separate, supplemental report prepared by SCS. Each month, RRC and BroadRock must submit written reports to DEM on the total daily flow, maximum daily flow, and minimum daily flow of landfill gas, and identify wells where there were exceedances of operating requirements or where positive pressure exists. On a weekly basis, they must submit written reports on the operation of the existing control devices that include information on when a flare or engine went out of operation and when it came back into operation if the device was out of operation for more than one hour. BroadRock is constructing a new landfill gas-to-energy facility adjacent to the landfill and that facility, along with a significantly enhanced system to draw the gas from the landfill, is scheduled to become operational in the latter part of 2012. Transition from the existing system to this new configuration could be complex and must be carefully managed. The Order requires that within 30 days of receipt, the Respondents must submit a transition plan that describes the procedures or modifications to the landfill gas collection and control system that will be used to ensure that the transfer from the current to the new gas collection system shall not cause any odor issues beyond the property line of the Central Landfill facility. DEM intends to convene regular technical meetings among all the involved parties to monitor landfill gas conditions and oversee this important transition. Odors are created when landfill gases are not completely captured by the systems on site. This is checked through monitoring along the surface of the uncapped portions of the landfill. DEM intends to supplement the surface emission monitoring being done by the Respondents with additional monitoring by an independent environmental consultant. The Order includes a provision that requires the Respondents to implement certain actions outlined in their permits within three days of receiving written notification from DEM of a monitored exceedance of methane at any location on the Central Landfill if uncontrolled surface emissions are detected through this independent monitoring. The Respondents must acquire and maintain the capacity to apply Posi-Shell as cover material on the landfill within 30 days of receipt of the NOV. Posi-Shell, a spray-applied mineral mortar coating, shall be used if the flow of landfill gas makes it necessary to provide an effective barrier to the migration of landfill gas to the atmosphere. This is another action that RRC has voluntarily agreed to take; nonetheless this provision in the Order will formalize that agreement and ensure the availability of this material on-site. Lastly, within 30 days of receipt of the NOV, the Respondents must install and make available for use the new landfill gas flare that was approved by DEM and acquired by BroadRock on December 23, 2011. "I am optimistic that these additional steps will improve air quality around the landfill," added Coit. RRC and BroadRock Gas Services LLC have 20 days from the receipt of the NOV to request a hearing before DEM's Administrative Adjudication Division. Since October 2011, residents of Johnston and some surrounding communities have complained of a strong odor coming from the Central Landfill. These odors were confirmed through DEM inspections at and around the facility and on October 19, DEM issued a Letter of Noncompliance directing RIRRC to implement immediate actions to eliminate the objectionable odors being generated by the facility. In response to this letter, RRC submitted a corrective action plan on October 29. In early November, DEM took additional steps to directly monitor RRC's progress in implementing corrective actions and monitoring the odors experienced in the surrounding community. DEM's Office of Waste Management has been performing inspections of the landfill at least twice per week to determine the status of RIRRC's efforts to rectify the odor problem. In addition, DEM's Office of Compliance and Inspection has been conducting odor monitoring in the immediate area surrounding the landfill twice per week to determine the extent, duration, and strength of odors using instrumentation to measure hydrogen sulfide concentrations when odors are detected. In December DEM, working in conjunction with the Town of Johnston, installed air monitoring equipment in a secure location in Woodlake Park on Central Avenue that has provided a continuous measurement of the level of hydrogen sulfide in the air, along with data on wind direction and wind speed. The Department of Health has been using the data from this monitoring station to interpret the health significance of the hydrogen sulfide levels. Elevated levels of hydrogen sulfide are associated with a noticeable rotten-egg type odor. Hydrogen sulfide fumes can cause nausea, itchy eyes, breathing difficulties, or throat irritations. -30- |
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