Violation Notice
On the 19th of December, the Smiths Creek Landfill received a rather concerning 5th violation notice from EGLE, particularly regarding the air quality control division. The notice established and meticulously explained the various violations that the landfill had committed, providing all the necessary supporting documents that contributed to the notice.
Upon a thorough review of the notice, a number of inquiries emerged from concerned township officials, which prompted them to seek clarification from county officials. On December 21st, representatives from the township issued a list of 11 pertinent questions to county officials, with the hope of uncovering more information and obtaining satisfactory answers to the pressing concerns about the landfill’s practices.
Overall, it is vital that proper measures are taken not only to ensure the protection of the environment but also the safety of the public.
Our Questions
- Why weren’t SEM (surface emissions monitoring) inspections being done on cell 8? It is producing 600 cu ft of gas per minute and we weren’t monitoring the surface for gas emissions?
- Wellhead and system vacuum data showed evidence that the system wasn’t working as designed. Why wasn’t this addressed?
- Several collection wells showed evidence of vapor lock, water in the GCCS (gas collection & control system), etc. Why weren’t vertical wells constructed as required by law?
- The ROP renewal in November of 2022 showed gas production at the landfill of 9,178 cu ft per minute. According to the equipment inventory, that flow exceeds capacity of the GCCS. Why wasn’t this addressed?
- The landfills response to violation notices indicates that engineering and design are not the issue and that the system is sufficient to collect the gas. Why then did we have to add a flare and header for gas collection?
- It appears throughout this violation notice that we did not have an effective SEM. This included areas of dead vegetation which are a clear sign of issues. We also weren’t doing any SEM in some areas of the landfill? Why didn’t we have in place a more comprehensive SEM and how did we operate an SEM without covering all areas of the landfill?
- In June, a materials management inspection indicated that there were problems with final cover as did the EGLE SEM in October. Why wasn’t that resolved? Although if I’m not mistaken, Commissioners Simasko’s motion addressed this.
- EGLE stated that the landfill needed a permit for the new flare. Why didn’t the landfill get one?
- Why didn’t the landfill revise the design plan prior to adding new gas collection lines?
- Could this entire issue have been reduced in severity or even eliminated altogether if we had acted upon the warning signs or acted on the data showing potential issues or had a better SEM in place?
- Who is responsible for all of the above and how are we holding them accountable?
Moving Forward
The importance of obtaining the answers to the questions presented cannot be overstated. By investigating the cause of the landfill failure and identifying the specific processes necessary to prevent a recurrence, valuable insight can be obtained in order to inform future decision-making. Without this information, the potential exists for similar failures to occur, leading to further potential harm to the environment, the surrounding community, and the economy. By prioritizing and taking the necessary steps to ensure that the processes involved with the landfill are optimized for safety and efficacy, we can ensure that the landfill functions effectively for years to come. Through diligent record-keeping, ongoing monitoring, and the commitment of those responsible for the landfill’s operation and management, we can achieve the goal of minimizing any negative effects associated with its use.
