METHANE & THE COLLIER CO LANDFILL


26 October 2020



Department of Environmental Protection
Division of Air Resource Management
Office of Permitting and Compliance 
2600 Blair Stone Road MS #5505
Tallahassee, Florida, 32399-2400

RE: Comments/Concerns - Draft Air Permit No. 0210051-027-AC Waste Management, Inc. of Florida, Collier County Landfill Collier County, Florida

Sir/Madam,

Golden Gate Estates Area Civic Association (GGEACA) has concerns about the issuance of this air permit for an open flare. Golden Gate Estates is the largest residential community in Collier County and it borders the Waste Management, Inc (WMI) operation on its sw border.

In the last 10 years the residents of the Estates Community has had to deal with 2-3 major wildfires and 1 major open fire issue with an improperly operated vegetative recycling business (Environmental Turnkey Solutions; ETS) in Collier County.

In all cases there was insufficient attention paid to operational issues that led to these community threatening events.

In the case of the permit to be issued to Waste Management:

1.Methane is documented as a “highly flammable” gas. That can explode if ignited under certain circumstances.
2.Is the methane gas produced at the landfill a day to day significant ignition/fire source?
3.Are the vehicles, machines and other electrical devices operated onsite considered an “ignition source,” safe not to start an explosion / wildfire event in the community?
4.Can embers from an adjacent wildfire cause an explosion or enhance wildfire conditions to the methane gas source onsite?
5.Are there periodic checks to detect if methane is leaking from the source area?
6.This location is will be less than a 1000 feet from the Collier County Paridise Sports Park. Will the methane gas present and the flare a danger to this UNAWARE people from inhalation, fire or explosion?
7.Will smell be an issue to people using the Paradise Sport Park?
8.What are the emergency response protocols, procedures, neighborhood notifications for methane, fire, explosions?
9.WMI has never met with the community about safety

Looking forward to your responses.



Michael R. Ramsey
President, Golden Gate Estates Area Civic Association
www.ggeaca.org 


PERMITTEE 
Waste Management Inc. of Florida 
3750 White Lake Boulevard 
Naples, Florida 34117


PERMITTING AUTHORITY 
Florida Department of Environmental Protection (Department) 
Division of Air Resource Management 
Office of Permitting and Compliance 
2600 Blair Stone Road, MS #5505 
Tallahassee, Florida 32399-2400 

PROJECT 
Air Permit No. 0210051-027-AC 
Minor Air Construction Permit 
Collier County Landfill 
This project authorizes a like for like replacement of the currently permitted 3,000 standard cubic feet per minute (scfm) open flare (EU003). 

NOTICE AND PUBLICATION 
The Department distributed a draft minor air construction permit package on October 9, 2020. The applicant published the Public Notice in the Naples Daily News on October 14, 2020. The Department received the proof of publication on October 16, 2020. No requests for administrative hearings or requests for extensions of time to file a petition for administrative hearing were received.  

COMMENTS 
Public 
On October 26, 2020, the Department received comments from Michael R. Ramsey, on behalf of the Golden Gate Estates Area Civic Association. Mr. Ramsey states that in the last 10 years the residents of the Estates Community has had to deal with 2-3 major wildfires and 1 major open fire issue with an improperly operated vegetative recycling business (Environmental Turnkey Solutions; ETS) in Collier County, and that in all cases there was insufficient attention paid to operational issues that led to these community threatening events. The following summarizes the comments and the Department’s response. 

1. Is the methane gas produced at the landfill a day to day significant ignition/fire source? 

Response: By federal law (Title 40 of the Code of Federal Regulations (CFR), Part 60, Subpart WWW, Standards of Performance for Municipal Solid Waste Landfills, the Collier County Landfill is required to collect the landfill gas (LFG) generated from the decomposition of waste under anerobic conditions in the landfill. The LFG produced at the landfill primarily consists of 45-50 percent carbon dioxide, 45-50 percent methane, and trace amounts of nitrogen, oxygen, ammonia, sulfides, hydrogen, carbon monoxide, and nonmethane organic compounds (NMOCs). The collected LFG is passed through a gas treatment system and the sent to the five 0.8-megawatt spark ignition reciprocating internal combustion engines (RICE) to produce electricity. The remainder of the collected LFG is sent to the three existing open flares – a 3,000 standard cubic feet per minute (scfm) flare and two 1,200 scfm flares. Since the vast majority of the LFG generated by the landfill is collected and the combusted under controlled conditions via five RICE engines and the three open flares, the Department does not believe that the methane gas produced at the landfill is a significant ignition/fire source. 

2. Are the vehicles, machines and other electrical devices operated onsite considered an “ignition source,” safe not to start an explosion / wildfire event in the community? 

Response: This permitting action solely deals with the authorization the installation of a replacement flare to combust LFG generated by the landfill. This concern brought forth by the commenter is not germane to this permitting action. However, the replaced flare will ensure that along with the other RICE engines and other flares on site, the vast majority of generated LFG will be collected and combusted in a safe manner.. 

3. Can embers from an adjacent wildfire cause an explosion or enhance wildfire conditions to the methane gas source onsite? 

Response: Once again, this concern brought forth by the commenter is not germane to this permitting action. However, as previously stated, The vast majority of the generated LFG is collected and combusted under controlled conditions.  

4. Are there periodic checks to detect if methane is leaking from the source area? 

Response: 40 CFR 60, subpart WWW, referenced in response to comment 1 requires the landfill to operate the landfill gas collection system so that the methane concentration is less than 500 parts per million above background concentration at the surface of the landfill. To determine if this level is exceeded, the landfill is required to conduct quarterly surface testing around the perimeter of the collection area and along a pattern that traverses the landfill at 30 meter intervals and where visual observations indicate elevated concentrations of landfill gas, such as distressed vegetation and cracks or seeps in the cover. 

5. This location is less than 1000 feet from the Collier County Paradise Sports Park. Will the methane gas and the flare present a danger to this unaware people from inhalation, fire or explosion? 

Response: Please see responses to Comments 1 and 4.  

6. Will smell be an issue to people using the Paradise Sport Park? 

Response: The LFG collection system and associated combustion devices (RICE engines and flares) ensure that most LFG (main odor source for a landfill) is collected and destroyed. This permitting action, the like-for-like replacement of the 3,000 scfm open flare help in reducing instances of odors. Despite these efforts to control odors, if the people using Paradise Sport Park experience objectionable odors, please report them to the Department’s South District office by phone at (239) 344-5600 or by email at SouthDistrict@FloridaDEP.gov. 

7. What are the emergency response protocols, procedures, neighborhood notifications for methane, fire, explosions? 

Response: Pursuant to Section 403.077 of the Florida Statutes (F.S.), the Department has established a method for regulated entities to submit Public Notices of pollution for reportable releases. These notices are made available to the public by visiting https://floridadep.gov/pollutionnotice or by subscribing to the department’s e-mail subscription service. Interested parties may subscribe to this e-mail subscription by visiting https://floridadep.gov/pollutionnotice. To learn more about the safety protocols and procedures that the Collier County Landfill has in place, the Department encourages members of the Golden Gate Estates Area Civic Association to request a meeting with Waste Management Inc. or Collier County. 

8. Waste Management Inc. has never met with the community about safety. 

Response: Golden Gate Estates Area Civic Association may request a meeting with Waste Management Inc. or Collier County to discuss safety concerns that the community members have.  

CONCLUSION 
The final action of the Department is to issue the permit as drafted. 



WASTE MANAGEMENT INC (WMI) OPERATING AT THE COLLIER COUNTY LANDFILL RENEWS DEP AIR PERMIT TO BURN METHANE AT THE COLLIER COUNTY LANDFILL WITHOUT ANY DISCUSSION WITH THE ESTATES RESIDENTS?

Methane (CH4) is a colorless, odorless, highly flammable combustible gas. It is the main component in Natural Gas. It is created in landfills by the decomposition of organic waste. Landfills are required by law to collect the methane generated (CFR Part 60). However, it is left to the operator of the Landfill (WMI) on how to collect and how to dispose of it. WMI chooses to burn it.

The biggest problem with a gas like methane or natural gas is making sure there are NO LEAKS, and NO ACCIDENTAL IGNITIONS that could lead to explosions.

Leaks that are not known/found can cause huge explosions, i.e. the San Bruno, California Pipeline Explosion. Natural Gas was leaking at a certain location for a period of time. The amount of gas built up in a small area, then an unknown ignition source caused the explosion.

On 02 Oct 2020, WMI applied to DEP to replace a 3000 scfm flare to burn the methane generated by the landfill. On 14 Oct 2020 WMI published a Public Notice in the Naples Daily News of their intention to replace the flare.

In the Public Notice for the permit renewal, DEP allows the public 14 Days to make comments about concerns for this type of activity, burning off methane with flares. 26 October 2020GGEACA did submit a letter stating concerns.  Click here for GGEACA’S letter. Or see below.

After the GGEACA letter is DEP’s response to concerns. DEP issued the permit 0210051-027-AC to WMI on 06 Nov 2020. DEP included their responses to GGEACA’s concerns in “attached documents” after the permit was issued.  Click here for DEP responses. Or see below.

GGEACA has never been contacted or shown any concern by WMI or Collier County about the buildup of methane gas, or safety measures next to the Golden Gate Estates Community or the Paradise Sports Park.

Maybe more attention needs to be paid to this issue before there is another Environmental Turnkey Solutions Mulch Fire or San Bruno California Gas Leak and explosion here in the Estates. In both cases it was nobody’s fault, because NOBODY WAS WATCHING.

Let us know what you think…………