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Overview – Inadequate Flare Design/Operation Contributes to Excess Emissions and Odors
The Michigan Department of Environment, Great Lakes, and Energy (EGLE), Air Quality Division (AQD) issued a Violation Notice to the owner of the Arbor Hills Landfill, Green for Life (GFL), on November 10, 2021. The Violation Notice alleges the Flare System at the Arbor Hills Landfill has not been adequately designed and/or operated to capture and burn all the landfill gas typically produced at the landfill. EGLE believes that failing to capture and control all the gas produced likely contributed to odors detected in the downwind community.
Landfill Emission Control System
Figure 1 is a very simplified representation of the emission control system at the Arbor Hills Landfill.
Figure 1 - Arbor Hills Emission Control System
The Landfill has over 400 gas wells which are monitored and “tuned” to optimize the capture of gas produced by the landfill’s degradation process.
Blowers (compressors) are used to transport the landfill gas in pipes from the gas wells to the emission control equipment where the gas is burned to destroy odorous and potentially hazardous materials. The blowers maintain a vacuum on the landfill gas piping to extract the gas from the landfill.
The landfill “gas to energy plant” is the primary emission control equipment. The flare system is secondary or backup emission control equipment. Gas is only directed to the flares if the "gas to energy plant" is shut down or the capacity of the "gas to energy plant” is exceeded.
The flare system must be designed to handle 100% of the landfill gas expected to be generated.
If the capacity of the flare system is not adequate and reliable, excess landfill gas will vent directly to the ambient air. These uncontrolled emissions may contain hazardous materials and noxious odors.
EGLE’s Survey
Inspectors from EGLE used the landfill gas flow rates measured immediately before and during 3 recent shutdowns of the landfill “gas to energy plant”. This analysis determined that during the “gas to energy plant” shutdowns, less than 90% of the landfill gas that was measured just before the shutdowns was being captured and destroyed by the flares. There was a shortfall of between 1,000 SCFM and 1,800 SCFM of gas being destroyed during the energy plant shutdowns.
During the “gas to energy plant” shutdown on October 18th and 19th problems with the operation of one flare were documented, a shortfall in the gas captured was measured, and the community submitted 18 odor complaints. In addition, a Conservancy Initiative member spotted what appeared to be deodorant being applied to mask the odors emanating from the north side of the landfill.
Figure 2 - Landfill Deodorant?
Repeat Violations
The flare system represents a critical piece of emissions control equipment. EGLE has issued several violations for inadequate design and operation of this critical emission control equipment in the past. The most significant past violation was issued on 2/7/2019 when EGLE found many deficiencies with the design and capabilities of the flare system.
Below is a list of the past flare system violations. This list is included to create an accurate record of this past poor performance. Copies of the past Violation Notices can be found at http://www.deq.state.mi.us/aps/downloads/SRN/N2688/
Table 1 - Past Violations Involving Flare System
Related Lawsuits
The owners of the Arbor Hills Lanfill, GFL, and the Gas to Energy Plant, Arbor Hills Energy are both involved in other lawsuits involving enviromental compliance. It can be difficult for the occassional reader to not confuse these lawsuits. Below is a simplified list of the active environmental lawsuits related to the Arbor Hills site.
Figure 1 - Active Environmental Lawsuits Related to Arbor Hills Site