Review Of Hydrogen Sulfide Gas - Abatement Options

356 Pages·2014·17.56 MB·English

Prepared for
Environmental Enforcement Section
New Jersey Division of Law
R.J. Hughes Justice Complex
25 Market Street
Trenton, New Jersey 08625

REVIEW OF HYDROGEN SULFIDE GAS
ABATEMENT OPTIONS

FENIMORE LANDFILL
ROXBURY TOWNSHIP, NEW JERSEY

Prepared by
10220 Old Columbia Road, Suite A
Columbia, Maryland 21046
Project Number: ME1035
March 2014
EXECUTIVE SUMMARY

Geosyntec Consultants was retained to review potential abatement options for mitigating
severe hydrogen sulfide (H S) gas odors at the Fenimore Landfill. Options considered
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include (i) targeted removal of gypsum-containing materials; (ii) removing all of the fill
material for disposal at off-site landfills; or (iii) leaving the fill material in-place and
constructing a final closure cap with H S gas control system. The review included
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estimating H S and other emissions from each option, identifying the ability of each
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option to control H S emissions, and comparing the ability of each option to minimize
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impacts to the community surrounding the site. In addition, a cost estimate for complete
removal of fill material was performed.

The analysis performed supports the conclusion that capping the fill material in-place is
the most feasible option. This is based on the following:
• Targeted removal of gypsum-containing materials is not feasible because these
materials are spread throughout the site.
• During removal of fill materials off-site for disposal, it is likely the community
will experience significant odor and/or potential health issues because uncontrolled
H S gas will be released into the community from both the active construction
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zone and trucks traveling on roads as materials are hauled off-site. This will occur
during an estimated 16 month period required for excavation and removal, 24
hours a day, 7 days a week.
• Capping fill material in-place will allow for controlled collection and management
of H S gas and will effectively encapsulate and reduce the generation of H S gas.
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This will significantly improve the performance of the existing gas collection and
treatment system, effectively managing H S gas odors.
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• Capping fill material in-place will address the goal of long-term mitigation of H S
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gas faster than other options, with significantly less truck traffic on local roads and
associated diesel fuel emissions from trucking and construction equipment.
• Removal of fill materials off-site for disposal will cost approximately 5 times that
of capping in-place, $38.7 million versus $7.4 million.
TABLE OF CONTENTS
1. INTRODUCTION AND PURPOSE .................................................................... 1
2. BACKGROUND .................................................................................................. 2
3. OFF-SITE REMOVAL OF FILL MATERIAL ................................................... 3
3.1 Partial Removal of Gypsum Containing Materials...................................... 4
3.2 Schedule....................................................................................................... 5
3.3 Hydrogen Sulfide Emissions ....................................................................... 6
3.3 Emissions from Trucking and Construction Equipment ............................. 7
4. REVIEW OF CLOSURE CAPPING ................................................................. 11
4.1 Schedule..................................................................................................... 12
4.2 Hydrogen Sulfide Gas Emissions .............................................................. 12
4.3 Emissions from Trucking and Construction Equipment ........................... 13
5. COST ESTIMATES ........................................................................................... 13
6. ANALYSIS......................................................................................................... 14
7. CONCLUSIONS ................................................................................................ 16

FIGURES
Figure 1: Distribution of Gypsum Materials within the Site
Figure 2: Schedule for Removal of Fill Material
Figure 3: Queuing area for Trucks Accessing the Site
Figure 4: Hydrogen Sulfide Gas Emissions Curves
TABLE
Table 1: Cost Estimate for Removal of Fill Material
PHOTO LOG
LIST OF EXHIBITS
Exhibit 1: NJDEP Administrative Consent Order dated 6 October 2011
Exhibit 2: Fenimore Landfill, Monthly MAP Material Amounts, compiled by
NJDEP from SEP reports dated 23 July 2013
ME1035/MD14073.doc i
TABLE OF CONTENTS (Continued)

Exhibit 3: Ibid
Exhibit 4: Ibid
Exhibit 5: Fenimore Fact Sheets by NJDEP dated 16 July and 22 October 2013
Exhibit 6: NJDEP Emergency Order dated 26 June 2013
Exhibit 7: Handex Consulting and Remediation, Vent #1 and #5 Analytical Report
No. 0813-134
Exhibit 8: New Jersey Department of Health Fact Sheet on Hydrogen Sulfide
Exhibit 9: Web site for All Site Structures at http//www.allsitestructures.com
Exhibit 10: Birdsall Services Group and Terracon Consultants monthly reports
Exhibit 11: Anderson R., et al. (2010). Modeling of Hydrogen Sulfide Generation
from Landfills Beneficially Utilizing Processed Construction and
Demolition Materials, Final Report for Environmental Research and
Education Foundation, Alexandria, Virginia
Exhibit 12: Tolaymat, T., et al. (2013). Estimate of the Decay Rate Constant of
Hydrogen Sulfide from Drywall in a Simulated Bench-Scale Study J.
Environ. Eng., 139(4), 538–544
Exhibit 13: US EPA 40 CFR Parts 85, 86, 600, 1033, 1036, 1037, 1039, 1065, 1066,
and 1068 / DOT 49 CFR Parts 523, 534, and 535, Greenhouse Gas
Emission Standards and Fuel Efficiency Standards for Medium and
Heavy-Duty Engines and Vehicles, 2011. Available at
http://www.gpo.gov/fdsys/pkg/FR-2011-09-15/pdf/2011-20740.pdf,
accessed January 2014
Exhibit 14: US EPA 40 CFR Parts 69, 80, and 86, Control of Air Pollution from New
Motor Vehicles – Heavy Duty Engine Vehicle Standards and Highway
Diesel Fuel Sulfur Control, 2001. Available at
http://www.gpo.gov/fdsys/pkg/FR-2001-01-18/pdf/01-2.pdf >, accessed
January 2014
Exhibit 15: US EPA 420-R-20-005, Updated Heavy-Duty Engine Emission
Conversion Factors for MOBILE6, 2002. Available at
http://www.epa.gov/otaq/models/mobile6/r02005.pdf , accessed January
2014
Exhibit 16: South Coast Air Quality District, CEQA Air Quality Handbook, 1993.
Available at http://www.aqmd.gov/ceqa/handbook/offroad/offroad.html,
accessed January 2014
Exhibit 17: US EPA A42 5th Edition. Available at
http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s02-3.pdf, accessed
January 2014
ME1035/MD14073.doc ii
TABLE OF CONTENTS (Continued)

Exhibit 18: Design Plans entitled “Fenimore Landfill, Partial Landfill Closure
Project, Roxbury Township, Morris County, New Jersey,” dated 31
January 2014 by the Louis Berger Group, Inc. RESERVED PENDING
PROCUREMENT.
Exhibit 19: Ibid
Exhibit 20: Table 1, Partial Landfill Closure Project, Preliminary Estimate for Partial
Landfill Closure dated 14 February 2014. RESERVED PENDING
PROCUREMENT.
Exhibit 21: Barlaz, M. et al. (2009) Controls on Landfill Gas Collection Efficiency:
Instantaneous and Lifetime Performance. J. of Air and Waste Manage.
Assoc., 59, 1,399-1,404
Exhibit 22: Ibid
Exhibit 23: Table 1, Partial Landfill Closure Project, Preliminary Estimate for Partial
Landfill Closure dated 14 February 2014. RESERVED PENDING
PROCUREMENT.
Exhibit 24: New Jersey Department of Health Hazardous Substance Fact Sheet

ME1035/MD14073.doc iii
1. INTRODUCTION AND PURPOSE
This report has been prepared by Geosyntec Consultants (Geosyntec) for the
Environmental Enforcement Section of the New Jersey Division of Law (NJDOL) in
the review of emergency actions taken to abate hydrogen sulfide (H S) gas emissions
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from the Fenimore Landfill in Roxbury Township, New Jersey. Geosyntec was retained
by NJDOL to perform a review of long-term options available to address observed
conditions at the site.
This report was prepared by Thomas Ramsey, P.E. as was reviewed by R. David
Espinoza, Ph.D., P.E. in accordance with the Geosyntec’s internal review policy.
The evaluation presented herein is based on observations made during Geosyntec’s 19
September 2013 site visit, footnoted exhibits within this report, as well as review of the
following information:

• Monthly landfill reports (including waste receipts) for June 2012 through May
2013 prepared by Birdsall Services Group and Terracon Consultants, Inc.
• LFG emission data from July, August, and September 2013;
• NJDEP Administrative Consent Order with Strategic Environmental Partners
(SEP) dated 6 October 2011;
• NJDEP Emergency Order dated 26 June 2013;
• NJDEP status reports from June, July, August, and October 2013; and
• A July 2010 presentation prepared by Matrix New World (MNW) describing the
proposed redevelopment of the site.
ME1035/MD14073.doc 1
2. BACKGROUND
In October 2011, the New Jersey Department of Environmental Protection (NJDEP)
signed an Administrative Consent Order with Strategic Environmental Partners (SEP)
that would provide for closure of Fenimore Landfill and the development of solar
photovoltaic panels over most of the 60-acre site1. As part of the development, fill
material was brought to the site between December 2011 and June 20132. Based on fill
material receipt records obtained from SEP by NJDEP3, the fill material consisted of
approximately 54 percent shredded demolition debris that contained a high fraction of
gypsum wallboard, with the remainder consisting of soils, crushed glass, asphalt
millings, and other comparatively inert materials. The total volume placed was
estimated to be approximately 375,366 cubic yards4. Beginning in late 2012, odor
complaints related to high levels of hydrogen sulfide (H S) gas were registered in the
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surrounding community5. Odor complaints worsened progressively, and on 26 June
2013, the NJDEP issued an Emergency Order assuming full control of the Fenimore
Landfill with the expressed goal of abating extremely high levels of H S gas measured
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at the site and the associated off-site odors issues that have been created6.
NJDEP retained Handex Consulting and Remediation to implement interim measures to
abate the H S gas issue at the site until final abatement measures can be implemented.
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Interim activities taken through February 2014 at the Fenimore Landfill to attempt to
abate H S gas include the following:
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• Covering approximately 19 acres of exposed fill material with Posi-shell®;
• Installation of nine vertical LFG collection wells within the fill along with
header piping in order to collect LFG;
• Installation of equipment for thermal destruction of LFG combined with
scrubbing of sulfur dioxide (SO ) from the resulting emissions;
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• Placement of compost and wood chips over areas where H S is observed to be
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escaping (fugitive gases) from the landfill as a means to treat H S;
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1 NJDEP Administrative Consent Order dated 6 October 2011.
2 Fenimore Landfill, Monthly MAP Material Amounts, compiled by NJDEP from SEP reports dated 23
July 2013.
3 Ibid.
4 Ibid.
5 Fenimore Fact Sheets by NJDEP dated 16 July 2013 and 22 October 2013.
6 NJDEP Emergency Order dated 26 June 2013.
ME1035/MD14073.doc 2
• Installation of natural gas, water, and electrical utilities necessary to operate the
LFG collection and SO emission control equipment; and
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• Design work to increase the number of LFG collection wells to 21 and install an
impermeable cap over the exposed fill material.
In September 2013, Geosyntec was retained to perform a technical review of the interim
measures to date along with the development of additional recommendations to plan
short-term and medium-term measures that would abate H S gas issues prior to
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implementation of permanent H S abatement measures. In December 2013, Geosyntec
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was subsequently retained to provide expert services for litigation associated with the
site. As part of these services, Geosyntec was requested to review environmental data
and cost estimates associated with mitigating the odor issues at Fenimore by either: (i)
targeted removal of gypsum-containing fill material for removal and off-site disposal
(ii) removing all the fill material to off-site disposal facilities; or (iii) leaving the fill
material in-place and constructing an impermeable cap with H S gas control system.
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3. OFF-SITE REMOVAL OF FILL MATERIAL
Two of the available options for abating observed conditions at the Fenimore site
involve excavating and removing some or all of the existing fill material, transporting
them for disposal at an off-site landfill. The plan of action for these options would
include the following major activities:
1. Mobilization of a contractor and equipment to the site to perform the work.
2. Installation of erosion and sediment control measures. Given the site of the area
to be disturbed (approximately 20 acres), a sediment control basin would be
required. There is an existing stormwater basin that dates to the initial
placement of waste at the site in the 1960s and 1970s and it is assumed that it
would be rebuilt and retrofitted for this purpose.
3. Construction of on-site temporary roads to provide access by over-the-road
dump trucks to be loaded in the area where fill material is being excavated.
4. Excavation of fill material with loading into over-the-road dump trucks.
5. Placement of 1 foot of cover soils plus 6 inches of topsoil following removal of
fill material and establishing permanent vegetation.
Of concern for removal of fill material is health and safety associated with the work.
Recorded H S gas concentrations sampled from within the fill material have exceeded
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ME1035/MD14073.doc 3
250,000 ppm7, which the New Jersey Department of Health has identified can cause
health issues8. As a result, health and safety precautions for fill material removal will
be extensive, including supplied air for workers within the safety exclusion zone around
the excavation and continuous air monitoring for workers located outside the exclusion
zone.
One concept for reducing the potential for uncontrolled H S gas emissions is to install a
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cover over the excavation area and use large air-handling equipment to collect
emissions from the excavation area as they are generated and treat them prior to
discharge into the air. A typical structure for an excavation operation would require a
clear working area of approximately 50 feet by 100 feet with a ceiling height of 25 feet
to allow heavy equipment to work. Temporary structures such as fabric-covered steel
buildings are available and can be supplied with the size and shape to allow excavation
equipment and trucks to work9. However, there are a number of significant issues that
would prevent the use of such structures. First, the structure would have to be secured
over rough and steeply sloped terrain. As a result, extensive work would be required to
make the soils on which the building rested suitable for use. Second, temporary
structured require significant anchoring to prevent their movement in windstorms.
Anchoring systems typically include screw piles, concrete piers, or securing the
building frame to prefabricated concrete anchors. Because waste excavation results in
the movement of operations every few days, the temporary structure would have to be
disassembled, moved, and anchored every few days as well. As a result of these
substantial difficulties, the use of a temporary building is not feasible. Therefore, waste
excavation would have to take place in the open and uncontrolled H S gas emissions, as
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described in Section 3.2 below, would occur.
3.1 Partial Removal of Gypsum Containing Materials
The first option reviewed for H S abatement is the partial removal of fill material with a
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focus on selectively removing gypsum-containing fill material (shredded demolition
debris). To determine the feasibility of this option, Geosyntec reviewed monthly
reports prepared by Birdsall Services Group and Terracon Consultants during placement
of fill material10. As part of these reports, the placement of fill material was tracked by
dividing the site into a grid and then noting which grid received fill material in the
month it was placed. By reviewing these records for the location and date of placement

7 Handex Consulting and Remediation, Vent #1 and #5 Analytical Report No. 0813-134.
8 New Jersey Department of Health fact sheet on Hydrogen Sulfide.
9 Web site for All Site Structures at http//www.allsitestructures.com
10 Birdsall Services Group and Terracon Consulting monthly reports.
ME1035/MD14073.doc 4
of gypsum-containing fill material, an assessment can be made whether the material is
widespread across the site or concentrated into localized areas. As shown on Figure 1,
the gypsum-containing fill material appears to have been spread throughout the fill
material during many months. Therefore, the gypsum-containing fill material cannot be
selectively removed from the site without disturbing all fill material. As a result, this
option is not considered feasible and has been removed from further consideration.
3.2 Schedule
As shown in Figure 2, Geosyntec prepared an estimated schedule for the removal of all
fill material for off-site disposal. Based on the roughly T-shaped fill material disposal
area, the steep slopes leading to the base of the fill materials, the small size of the total
area being excavated, and the one-way access road leading into and out of the site (see
photo log), the critical path item for removal of wastes will be the ability to load and
haul materials off-site. Based on a potential queuing area that is approximately 40 feet
wide and 600 feet long, (see Figure 3) the total number of dump trucks that can service
the site at any one time is estimated to be 24.
As previously mentioned, it is important to note that health and safety precautions for
fill material removal will be extensive. Supplied air will be required for heavy
equipment operators and a safety exclusion zone will be maintained around the
excavation with continuous air monitoring along the perimeter of the exclusion zone.
Truckers approaching the excavation for loading will have to temporarily use supplied
air as well. These conditions will significantly limit the productivity of fill material
removal work as compared to typical construction operations where air emissions do
not create a health and safety hazard.
Because of these conditions and the distance to the nearest commercial landfill
(approximately 40 miles one way), it is assumed that each truck will only be able to
remove three loads of fill for off-site disposal per day. Based on a capacity of 15 cubic
yards of fill material per load, the total number of days required for waste removal is
calculated to be 318 working days, or 16 months. Following fill material removal, soil
must be imported to the site to cover the historic landfill that will remain. This effort,
plus establishing permanent vegetation to stabilize the site is assumed to extend the
schedule another 6 months, bringing the total construction period as shown on Figure 2
to 22 months.
ME1035/MD14073.doc 5