Advanced Disposal responded to MDEQ’s latest violation letter regarding the High Temperature Landfill (HTLF) event. We have not seen a response from Fortistar, but suspect Advanced is taking the lead on this issue.
View abridged response | View full response
The response letter appears to be written by a different author or editor. The new landfill manager, Mark Johnson, seems to be getting his feet on the ground and taking charge. In the letter, Advanced Disposal takes exception to some of MDEQ’s claims in the Violation Notice.
…we must respectfully disagree with certain statements in the VN [violation notice] regarding when AQD became aware of elevated landfill temperatures, the timeliness of diagnosis and implementation of corrective actions by Arbor Hills, the elevated temperature event not being contained, and ramifications associated with these temperatures
Advanced presents evidence that MDEQ Air Quality Division (AQD) was alerted to high gas collection and control system (GCCS) well temperatures in an isolated section of the landfill in May 2016, understood the cause of the high temperatures and took corrective actions at that time.
This area of the landfill has exhibited elevated temperatures since May 2016, which AQD has been aware of since at least November 2016 as indicated in AQD’s HOV approval letter to BFI… dated December 2, 2016.
…Arbor Hills also communicated the elevated temperatures seen in gas wells in this area of the landfill are believed to be due to the non-methanogenic degradation of a special waste stream previously accepted at the landfill.
Terminating acceptance of this special waste stream, the source of the elevated temperatures, was a timely corrective action taken by Arbor Hills.
Advanced Disposal believes their corrective actions have been effective in containing the HTLF event as the HTLF event has not spread significantly since 2016.
While the number of wells with elevated temperatures has increased since 2016, the overall bounding area of the elevated temperatures within the landfill has remained essentially unchanged based on the location of wells …
Advanced Disposal downplays the ramifications of the HTLF event is doing to the gas system at the landfill.
Elevated temperatures are just one of many conditions present within the landfill environment that can negatively impact a landfill’s gas collection and control system (GCCS). Arbor Hills replaces GCCS infrastructure when its physical integrity has been compromised. Based on historical gas well replacement data, the frequency of GCCS infrastructure replacement in the elevated temperature area is actually less than seen in other areas of the landfill.
Advanced Disposal is asking for MDEQ’s help in correcting the HTLF event. Advanced has proposed drawing more gas off the wells with the elevated temperatures in an attempt to pull the heat away from this area of the landfill. Normally, gas flows from wells with elevated temperatures are reduced as a precaution to prevent potential fires. Landfill operators can request permission to operate at higher temperatures (called a Higher Operating Value or HOV request) but must demonstrate the higher temperatures do not pose a risk of fire (i.e. – the source of high temp is O2 and/ CO present).
Advanced recently requested MDEQ approval of an HOV for several gas wells in the area of the high temperatures and believes increasing gas flow in this area is necessary to extract heat from this area.
MDEQ initially denied this request but Advanced is asking MDEQ to reconsider.
Arbor Hills needs to open up the valves on the wells in this elevated temperature area to extract the heat, thereby lowering the temperature, consistent with accepted industry best practices for these type events.
The Conservancy Initiative does not pretend to have the answers to these highly technical questions. Stay tuned. What we do know is that all the attention that the community is bringing to this sad landfill is working. THANK YOU!
The Conservancy Initiative has filed a “Letter Of Intent” to sue the landfill for violations of the Clean Air Act
The management of the landfill has changed
The MDEQ has stepped up its efforts
Northville Township formed a citizen committee to regularly discuss strategies to deal with the landfill
Local legislators are paying attention, even sponsoring legislation
We are making regular media appearances to keep the issue fresh
Thank you to everyone who has participated and/or contributed. There is much more to be done. Contact Tracey at info@theconservancyinitiative.org if you would like to help.