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The Michigan Department of Environment, Great Lakes, and Energy (EGLE) issued two new Violations Notices to Advanced Disposal Services this week. This brings the number of Violations Notices to at least 8 this year. Both Violation Notices were repeat violations (i.e. – similar violations have been cited and obviously not corrected). Both Violations Notices are the result of recent malfunctions to the landfill flares which resulted in excess emissions and likely community odors.
The primary purpose of the three flares at the Arbor Hills Landfill is to protect the surrounding community and environment by combusting landfill gas in the event the primary emission control equipment, the Landfill Gas to Energy Plant (a.k.a.- Arbor Hills Energy), is shut down for any reason. It is critically important that 100% of the landfill gas is continuously collected and combusted to control toxic emissions and noxious odors even when the Energy Plant is shut down. The combustion process oxidizes toxic materials contained in landfill gas including highly odorous hydrogen sulfide (H2S) to less odorous sulfur dioxide (SO2).
Violation Notice N2688_VN_20201014a
On September 23rd and 24th, DTE required a shutdown of the Arbor Hills Energy (AHE) Plant. During the Energy Plant shutdown …
…the two enclosed flares failed to reach and maintain required minimum operating temperature, triggering several alarms and periodic shutdowns/start-ups. The flares failed to operate as designed resulting in a period when the overall flaring capacity was much less than the normal gas flow generated by the landfill.
The Energy Plant shutdown and flare malfunctions were reported to EGLE only after EGLE contacted Advanced Disposal to ask them to investigate the odor complaints being made by the community. The Energy Plant Shutdown and the flare malfunctions likely resulted in significant community odors. The chart below highlights odor complaints on the days of the flare system malfunctions.
In addition to implementing corrective actions, EGLE is requiring ADS to test the flare system at full capacity (i.e. – shut down the Energy Plant) monthly to prevent the reoccurrence of these malfunctions.
The Conservancy Initiative is requesting EGLE requires “timely community notification of the Northville Township Community” whenever the Energy Plant is shut down, including prior to these monthly tests (similar to how Consumers Energy notifies the community before venting at their Napier Road facility). A simple notification to the adjacent neighborhoods seems like an action a good neighbor would gladly take. This notification requirement could be required in ADS’s Start up, Shutdown, Malfunction Abatement Plan (SSM) which EGLE is requiring to be updated as a result of these violations. An electronic mechanism for reporting the malfunctions (text or email to the Township and/or TCI) could be utilized to minimize the burden.
Violation Notice N2688_VN_20201014
On September 26th one of the three flares operated below the minimum required temperature for at least one hour. The Violation Notice does not contain details (how low was the temperature, how long was the event, etc.) but the violations appear to be less significant than the previously discussed violations.
These Problems Are Not New – Examples of Past Similar Violations
Issues with the operation and capacity of the flare system is not a new issue. A significant Violation Notice was issued on February 7, 2019, and ADS submitted a response on February 20, 2019. At that time, the flare system was found to be in very poor operating condition due to issues with the flare blowers and had no backup power supply. The flare system capacity was approximately 30% of the required volume. In their response ADS stated …
… DEQ [EGLE] has Arbor Hills' commitment to take all appropriate measures to remedy the blower issues as soon as possible
On February 27, 2020, EGLE issued a Violation Notice when ADS discovered it had been venting landfill gases directly to the atmosphere due to a bypass valve that malfunctioned on one of the flares. EGLE believed the malfunction was likely responsible for the 35 odor complaints submitted during three days in February 2020. ADS provided a lengthy response to the Violation Notice which included information to refute many of the community’s odor complaints.
… Based on our analyses, it is unlikely that the odor complaints logged by EGLE were due to this particular issue.
… The Site believes that it has taken aggressive actions to address the issue which led up to the malfunction, and has put systems in place to prevent future such occurrences.
Problems with operating a flare below the minimum required operating temperature is also not a new problem. On March 18, 2020, EGLE issued a Violation Notice when ADS reportedly operated the flares below the minimum operating temperatures.
TCI will be submitting a Freedom of Information Act (FIOA) request to obtain the details of these violations and will follow-up if any significant new details are discovered. Responses to these Violation Notices are required from ADS by November 4th.