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    Environmental Consultants 11260 Roger Bacon Drive 703 471-6150 Reston, VA 20190-5258 FAX 703 471-6676 www.scsengineers.com July 27, 2014 File No. 02204045.01 Mr. Dave Moreira Via Electronic Transmittal Senior District Manager Waste Management Disposal Services of Pennsylvania, Inc. 4 Liberty Lane West Hampton, New Hampshire 30842 Subject: Semi Annual Report of Required Monitoring: Title V Operating Permit No. 46-00033 Pottstown Landfill and Recycling Center Dear Mr. Moreira: SCS Engineers (SCS) is pleased to submit the enclosed Semi Annual Report of Required Monitoring for the Pottstown Landfill and Recycling Center (Pottstown LRC) in accordance with the Pottstown LRC’s Title V Operating Permit (No. 46-00033). This report covers the period of January through June 2014. One copy should be sent to PADEP and EPA Region III, postmarked no later than October 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 Quality Program Manager Pennsylvania Department of Environmental Protection, Southeast Region 2 East Main Street Norristown, Pennsylvania 19401 A responsible official for the site must complete the Certification page 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 Offices Nationwide


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    PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF AIR QUALITY SEMI-ANNUAL REPORT OF REQUIRED MONITORING (25 Pa. Code § 127.513) Facility Name: WASTE MGMT DSPL SVC/POTTSTOWN Plant Name: POTTSTOWN LANDFILL Contact Person: DAVID MOREIRA Title: SENIOR DISTRICT MANAGER Operating Permit #: 46-00033 Phone Number: (603) 929-5446 For the period 01/01/2014 – 06/30/2014, WASTE MGMT DSPL SVC/POTTSTOWN has been in continuous compliance with all applicable monitoring requirements of permit # 46-00033, determined by the method(s) of compliance specified in said permit, except for the following potential deviations: Sect./Cond Citation Monitoring Date # # Source Potential Deviation Method(s) Duration Corrective Action(s) --No instances of deviations from monitoring requirements as specified in the Title V Permit occurred during this reporting period-- Certification of Truth, Accuracy and Completeness Subject to the penalties of Title 18 Pa. C.S. Section 4904 and 35 P.S. Section 4009 (b) (2), I certify under penalty of law that, based on information and belief formed after reasonable inquiry, the statements and information contained in this form are true, accurate, and complete. Name: David Moreira Title: Senior District Manager Signed: Date: This certification must be signed by a responsible official. Any certification submitted without a valid signature will be returned. The owner/operator shall identify any other material information needed in this certification to also comply with section 113(c)(2) of the Clean Air Act. If more spaces are needed, complete additional pages using the format shown in Addendum 1. This certification does not replace requirements pertaining to the submission of malfunction and CEM reports. DO NOT include that information on this form.


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    PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF AIR QUALITY SEMI-ANNUAL REPORT OF REQUIRED MONITORING (25 Pa. Code § 127.513) ADDENDUM 1 For the period 01/01/2014 – 06/30/2014, WASTE MGMT DSPL SVC/POTTSTOWN has been in continuous compliance with all applicable monitoring requirements of permit # 46-00033, determined by the method(s) of compliance specified in said permit, except for the following potential deviations: Citation Monitoring Sect./Cond # # Source Potential Deviation Method(s) Dates and Durations Corrective Action(s)


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: Regular monitoring was conducted (see also Section C.010). [25 Pa. Code §§ Visible air contaminants may be measured using either of the No visible emissions were Continuous 123.43] (Measuring Section C (C.009) following: observed during the Techniques) Intermittent (1) A device approved by the Department and maintained… regular monitoring; as such no measurements were required during the reporting period. (a) The permittee shall monitor the facility weekly for the following: [25 Pa. Code §§ (1) Odors, pursuant to 25 Pa. Code §123.31(b). The permittee The permittee conducts 127.441] (Operating shall conduct an evaluation at the facility boundary. regular monitoring in Continuous Section C (C.010) Permit Terms and accordance with the Intermittent (2) Visible emissions, pursuant to 25 Pa. Code §123.41. The Conditions) permit. permittee shall conduct a visual evaluation of the emission sources from the facility boundary. If an exceedance of the applicable standard specified in 25 Pa. Code §123.41 is…. [25 Pa. Code §§ Section D (D.006) (a) The permittee shall annually calculate the Non-methane Annual calculations and Continuous 127.441] (Operating Source ID 101 – Organic Compound emission rate from the landfill based on the emissions reporting are Permit Terms and Landfill without Intermittent procedures specified in 40 CFR Section 60.754 for NMOC…. completed. Conditions) Eastern Expansion Monthly (at a minimum) monitoring of cover [40 CFR Part 60 integrity is conducted. Standards of (a) On a monthly basis, the permittee shall implement a program Section D (D.007) Quarterly (at a minimum) Performance for to monitor for cover integrity and implement cover repairs as surface emissions Continuous New Stationary Source ID 101 – necessary. monitoring (SEM) is Sources §40 CFR Landfill without Intermittent (b) The permittee shall monitor off-site migration of landfill gas conducted. Regular 60.755] (Compliance Eastern Expansion using the methods approved by the Department. review of these records is provisions) completed for preparation of the semi-annual NSPS operational reports. Page 1


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: Monthly (at a minimum) [40 CFR Part 60 monitoring of the wellhead Continuous1 Standards of Section D (D.008) The permittee shall monitor the temperature of the wellhead, temperature is conducted. Performance for Intermittent Source ID 101 – monthly, using a sampling port and a thermometer, other Regular review of these New Stationary Landfill without temperature measuring device, or an access port for records is completed for [Reference also Sources §40 CFR Eastern Expansion temperature measurements installed at each wellhead. preparation of the semi- Section D (D.002) 60.756] (Monitoring annual NSPS operational for Source ID 101] of operations) reports. Monthly (at a minimum) [40 CFR Part 60 monitoring of the gauge Continuous1 Standards of Section D (D.009) pressure at each wellhead Performance for Intermittent Source ID 101 – On a monthly basis, the permittee shall measure gauge is conducted. Regular New Stationary Landfill without pressure in the gas collection header at each well. review of these records is [Reference also Sources §40 CFR Eastern Expansion completed for preparation Section D (D.002) 60.756] (Monitoring of the semi-annual NSPS for Source ID 101] of operations) operational reports. The permittee shall perform surface monitoring in accordance Quarterly (at a minimum) [40 CFR Part 60 with the following, or in accordance with an alternative surface surface emissions Standards of Section D (D.010) monitoring plan approved by EPA and the Department. monitoring (SEM) is Performance for Continuous Source ID 101 – conducted. Regular New Stationary (a) On a quarterly basis, the permittee shall monitor surface Landfill without review of these records is Intermittent Sources §40 CFR concentrations of methane along the entire perimeter of the Eastern Expansion completed for preparation 60.756] (Monitoring collection area and along a pattern that traverses the landfill at of the semi-annual NSPS of operations) 30 meter intervals and where visual observations indicate… operational reports. 1 See regular NSPS operational reports. Page 2


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: On a monthly basis, the permittee shall monitor each well for Monthly (at a minimum) Section D (D.011) monitoring of the oxygen [40 CFR Part 60 nitrogen or oxygen to check for air infiltration into the landfill and and/or nitrogen at each Continuous1 Standards of Source ID 101 – to determine compliance with the operating parameters set forth Performance for Landfill without in Condition #002 [40 C.F.R. § 60.753(c). wellhead is conducted. Intermittent New Stationary Eastern Expansion Regular review of these (i) The nitrogen level shall be determined by using Method 3C or [Reference also Sources §40 CFR records is completed for [Reference also other Administrator approved method. Section D (D.002) 60.756] (Monitoring preparation of the semi- Section D (D.002) for Source ID 101] of operations) (ii) The oxygen level shall be determined by an oxygen meter annual NSPS operational for Source ID 101] using Method 3A or 3C. reports. (a) The permittee shall annually calculate the Non-methane Organic Compound emission rate from the landfill based on the [25 Pa. Code §§ Section D (D.009) procedures specified in 40 CFR Section 60.754 for NMOC, or as subsequently amended, or by alternative methods approved by Annual calculations and Continuous 127.441] (Operating Source ID 102 – the Department. emissions reporting are Permit Terms and Landfill Eastern Intermittent completed. Conditions) Expansion (b) The permittee shall determine annually the methane generation rate constant, “k” for use in calculating the NMOC emission rate. However, in lieu of determining a site-specific… The permittee installed Section D (D.010) and operates a flow meter [25 Pa. Code §§ and data recorder to Continuous 127.441] (Operating Source ID 102 – The permittee shall continuously monitor the gas flow rate record the flow rate Permit Terms and Landfill Eastern through the pipeline using a Department-approved methods. Intermittent through the pipeline. The Conditions) Expansion data is reviewed regularly for permit compliance. 1 See regular NSPS operational reports. Page 3


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: Monthly (at a minimum) monitoring of cover [40 CFR Part 60 integrity is conducted. Standards of (a) On a monthly basis, the permittee shall implement a program Section D (D.011) Quarterly (at a minimum) Performance for to monitor for cover integrity and implement cover repairs as surface emissions Continuous New Stationary Source ID 102 – necessary. monitoring (SEM) is Sources §40 CFR Landfill Eastern Intermittent (b) The permittee shall monitor off-site migration of landfill gas conducted. Regular 60.755] (Compliance Expansion using the methods approved by the Department. review of these records is provisions) completed for preparation of the semi-annual NSPS operational reports. Monthly (at a minimum) [40 CFR Part 60 monitoring of the gauge Continuous1 Standards of Section D (D.012) pressure at each wellhead Performance for Intermittent Source ID 102 – On a monthly basis, the permittee shall measure gauge is conducted. Regular New Stationary Landfill Eastern pressure in the gas collection header at each well. review of these records is [Reference also Sources §40 CFR Expansion completed for preparation Section D (D.004) 60.756] (Monitoring of the semi-annual NSPS for Source ID 102] of operations) operational reports. The permittee shall perform surface monitoring in accordance Quarterly (at a minimum) [40 CFR Part 60 with the following, or in accordance with an alternative surface surface emissions Standards of Section D (D.013) monitoring plan approved by EPA and the Department. monitoring (SEM) is Performance for Continuous Source ID 102 – conducted. Regular New Stationary (a) On a quarterly basis, the permittee shall monitor surface Landfill Eastern review of these records is Intermittent Sources §40 CFR concentrations of methane along the entire perimeter of the Expansion completed for preparation 60.756] (Monitoring collection area and along a pattern that traverses the landfill at of the semi-annual NSPS of operations) 30 meter intervals and where visual observations indicate… operational reports. 1 See regular NSPS operational reports. Page 4


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: On a monthly basis, the permittee shall monitor each well for Monthly (at a minimum) [40 CFR Part 60 nitrogen or oxygen to check for air infiltration into the landfill and monitoring of the oxygen Continuous1 Standards of Section D (D.014) to determine compliance with the operating parameters set forth and/or nitrogen at each Performance for in Condition #002 [40 C.F.R. § 60.753(c). wellhead is conducted. Intermittent New Stationary Source ID 102 – Regular review of these Landfill Eastern (i) The nitrogen level shall be determined by using Method 3C or [Reference also Sources §40 CFR records is completed for Expansion other Administrator approved method. Section D (D.004) 60.756] (Monitoring preparation of the semi- for Source ID 102] of operations) (ii) The oxygen level shall be determined by an oxygen meter annual NSPS operational using Method 3A or 3C. reports. Monthly (at a minimum) [40 CFR Part 60 monitoring of the wellhead Standards of Section D (D.015) The permittee shall monitor the temperature of the wellhead, temperature is conducted. Performance for Continuous Source ID 102 – monthly, using a sampling port and a thermometer, other Regular review of these New Stationary Landfill Eastern temperature measuring device, or an access port for records is completed for Intermittent Sources §40 CFR Expansion temperature measurements installed at each wellhead. preparation of the semi- 60.756] (Monitoring annual NSPS operational of operations) reports. An ongoing record of Section D (D.008) emissions is maintained [25 Pa. Code §§ The permittee shall calculate the VOC, CO, SOx, PM and NOx for annual and a 12-month Continuous 127.441] (Operating Source ID C05A – emissions from the enclosed flare on a monthly basis as well as rolling sum. The record is Permit Terms and Enclosed Flare 2 on a twelve (12) month rolling sum, using Department-approved Intermittent regularly reviewed in Conditions) (Installed ’97) methods. accordance with the permit. The permittee shall A record of flare operating (a) monitor the operating hour per calendar year hours is maintained. [25 Pa. Code §§ Section D (D.009) 127.441] (Operating (b) develop, maintain, and follow a Monitoring Plan for the The permittee developed a Continuous Source ID C05A – Permit Terms and annual NOx and CO monitoring of the flare. The Monitoring Monitoring Plan for NOx Enclosed Flare 2 Intermittent Conditions) shall involve using portable analyzers that are calibrated and and CO flare monitoring in (Installed ’97) operated in accordance with the manufacturer’s accordance with the recommendations. permit. 1 See regular NSPS operational reports. Page 5


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: The permittee shall calibrate, maintain, and operate according to Installation and operation the manufacturer’s specifications, the following equipment when of a flow meter, operating the enclosed flare. [40 CFR Part 60 thermocouple(s), and data Standards of Section D (D.010) (a) A temperature monitoring device equipped with a continuous recorder allows for Performance for recorder and having an accuracy of (+/-) 0.5 deg. C or (+/-) 32.9 continuous monitoring of Continuous New Stationary Source ID C05A – deg F, whichever is greater. the flow rate and Sources §40 CFR Enclosed Flare 2 temperature. Regular Intermittent (Installed ’97) (b) A gas flow rate measuring device that provide a 60.756] (Monitoring review of these records is measurement of gas flow to or bypass of the control device. of operations) completed for preparation The permittee shall operate, calibrate, and maintain a gas flow of the semi-annual NSPS rate measuring device that shall record the flow to the control operational reports. device at least every 15 minutes. Regular (daily at minimum) monitoring of the flow to [25 Pa. Code §§ Section D (D.007) each turbine is conducted. Continuous 127.441] (Operating The permittee shall monitor once per operating day for the flow Source ID C02 – This data is reviewed Permit Terms and rate of landfill gas to each of the turbines. Intermittent Turbine 2 regularly for evaluating the Conditions) turbine(s) monthly performance. (a) The permittee shall monitor the landfill gas once per unit Regular (daily at minimum) operating day to determine the composition of nitrogen, using monitoring of the nitrogen analytical methods and procedures that are accurate to within 5 content is conducted; [25 Pa. Code §§ percent and are approved by the Administrator to determine the regular monitoring of the Section D (D.008) 127.441] (Operating nitrogen content of the fuel being fired. Alternatively, the sulfur content is conducted Continuous Permit Terms and Source ID C02 – permittee may submit to the Department and EPA for approval per the required schedule. Intermittent Conditions) Turbine 2 an alternate plan for the monitoring of the composition of The data is reviewed nitrogen in the landfill gas. regularly in accordance (b) The permittee shall monitor the landfill gas on an annual with sulfur content basis to determine the composition of sulfur using Draeger ….. limitations specified. Regular monitoring of the (a) For the purpose of reports required under 40 C.F.R. Section LFG is conducted as [25 Pa. Code §§ Section D (D.009) 60.7(c), periods of excess emissions are defined and shall be required. The data is Continuous 127.441] (Operating reported as follows, samples of gaseous fuel obtained using Source ID C02 – reviewed regularly in Permit Terms and daily sampling, an excess emission occurs each unit operating Intermittent Turbine 2 accordance with Conditions) hour included in the period beginning on the date and hour of appropriate limitations any sample for which the sulfur content of the fuel being….. specified. Page 6


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    6 Month Report of Deviations from Monitoring Requirements, Pottstown Landfill: January through June 2014 Compliance with Monitoring Permit Monitoring Requirements Contained Means of Determining Requirement Citation Section in the Permit Compliance Status was: An ongoing record of emissions is maintained [25 Pa. Code §§ Section D (D.007) The permittee shall calculate the VOC, CO, SOx, PM and NOx for annual and a 12-month 127.441] (Operating emissions from the enclosed flare on a monthly basis as well as rolling sum. This record is Continuous Source ID C08 – Permit Terms and Enclosed Flare – on a twelve (12) month rolling sum, using Department-approved regularly reviewed in Intermittent Conditions) Eastern Expansion methods. accordance with the pollutant limitations specified. The permittee shall A record of flare operating (a) monitor the operating hour per calendar year hours is maintained. [25 Pa. Code §§ Section D (D.008) 127.441] (Operating (b) develop, maintain, and follow a Monitoring Plan for the The permittee developed a Continuous Source ID C08 – Permit Terms and annual NOx and CO monitoring of the flare. The Monitoring Monitoring Plan for NOx Enclosed Flare – Intermittent Conditions) shall involve using portable analyzers that are calibrated and and CO flare monitoring in Eastern Expansion operated in accordance with the manufacturer’s accordance with the recommendations. permit. The permittee shall calibrate, maintain, and operate according to Installation and operation the manufacturer’s specifications, the following equipment when of a flow meter, operating the enclosed flare. [40 CFR Part 60 thermocouple(s), and data Standards of Section D (D.009) (a) A temperature monitoring device equipped with a continuous recorder allows for Performance for recorder and having an accuracy of (+/-) 0.5 deg. C or (+/-) 32.9 continuous monitoring of Continuous New Stationary Source ID C08 – deg F, whichever is greater. the flow rate and Sources §40 CFR Enclosed Flare – temperature. Regular Intermittent Eastern Expansion (b) A gas flow rate measuring device that provide a 60.756] (Monitoring review of these records is measurement of gas flow to or bypass of the control device. of operations) completed for preparation The permittee shall operate, calibrate, and maintain a gas flow of the semi-annual NSPS rate measuring device that shall record the flow to the control operational reports. device at least every 15 minutes. Page 7


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