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Environmental Waste Solutions' Landfill in Camden

Background

The Environmental Waste Solutions (EWS) Landfill in Camden, TN is a Class II Industrial Landfill that has been approved to receive industrial waste including waste from companies that recycle aluminum. The Landfill has been in operation since January 2010. Early in 2011, the Department began to receive complaints about an ammonia odor from the landfill. Ammonia is generated when the aluminum waste comes into contact with water. The Department began working with EWS in the spring of 2011 to resolve the ammonia odor problem.

The Department first entered into a Compliance Agreement and then a Consent Order, requiring EWS to resolve the ammonia problem from the landfill. As a part of the Consent Order, EWS has installed a synthetic liner (a part of the soil gas recovery system) over the old waste cell. This work was performed the week of January 16, 2012. Since the cover was installed we have not had complaints from neighbors about ammonia odors. The Department assessed a civil penalty of $10,000 against EWS because EWS did not complete closure of the old waste cell as required in the Consent Order that was issued on July 22, 2011.

All new waste disposed at the site is being placed in the new waste cell that is equipped with a soil gas collection system. No waste has been placed into the old cell since the new waste cell was opened. The newly constructed waste cell has an improved design compared to the old cell. The new cell includes a soil gas collection system, daily monitoring and repair of any portions of the landfill with gas releases, continued operation of the on-site ambient air monitoring system, the addition of an off-site ambient air monitoring station and implementation of dust control measures on-site. A landfill gas leak detection and repair (LDAR) plan has been submitted and is under review by the Department.

Air Monitoring

TDEC has consulted with the Tennessee Department of Health (TDH) about the impact of ammonia vapors in the community based on air monitoring results. TDH is evaluating air monitoring data and reports from field staff. TDH indicates that the level of ammonia measured around the landfill is more than what is naturally found outdoors.

The Department employed an independent Environmental Consultant, SAIC, to collect air samples at 8 locations around the landfill twice per day on December 28, 29 & 30, 2011. Ammonia was only detected at two locations and then only sporadically. TDH has received this information to use in their analysis of community health. View SAIC Report.

The Department has installed an air monitor off-site, in the local community, to measure ammonia concentrations. That monitor has been installed and in operation since Thursday, January 19, 2012. This is a continuous sampling device and reports ammonia data to the Department electronically. This air monitor will be in operation for 90 days in the local subdivision. After that, the monitor will be moved to a different location that is directly downwind of the site and operated for 90 days at that location. Learn more about TDEC’s Ammonia Monitoring Initiative and view the data.

Current Status

We recognize the ammonia odors are of concern to local residents and we share those concerns. TDEC believes the ammonia vapor problem has been primarily resolved. We have not had ammonia complaints since the synthetic landfill cover was installed over the old waste cell. The Department believes the new waste cell is not contributing to the odor issue because of the requirement to install and operate a soil gas collection system in the new cell as a part of its design.

We have received complaints about “dust” coming from the placement of aluminum waste into an on-site storage building. The Department has asked EWS to add dust control measures to the building to prevent any dust from leaving the building when placed there. The reason for on-site storage is to provide an option for storage of the waste when it is raining or the ground is saturated from rain. The aluminum waste reacts with water to generate ammonia.

Ammonia Monitoring Initiative

Current Air Monitoring Results

Current Results through December 31, 2012

Current Results through February 27, 2013

Investigation Background Information

The Tennessee Division of Air Pollution Control (TDAPC) in cooperation with the Tennessee Division of Solid Waste Management (TDSWM) will conduct a short-term ambient air monitoring study in Camden, TN beginning January 19, 2012 to characterize ammonia emissions from Environmental Waste Solutions, LLC (EWS). EWS operates a landfill located in Benton County at 200 Omar Circle, Camden, Tennessee. The length of this study will be at least six months with sampling to be conducted for approximately 90 days in two different locations.

This study is being conducted in response to complaints from citizens in the community regarding emissions to the ambient air from the facility that may be impacting public health. Although ammonia may be released from several sources, primary concern has focused on ammonia released from the EWS facility. Based on the specific nature of the facility, the primary pollutant of concern will be ammonia released from dross buried in the EWS operated landfill. The goal of this monitoring effort is to collect air monitoring data of sufficient quality and quantity to determine if ammonia emissions are impacting areas outside of the landfill property boundary.

Investigation Locations

The first location selected for the study will be in a vacant lot on Sylvan Drive next to property owned by Mr. Mark Totty. The following photograph depicts the site and equipment installed on January 19, 20012. This site is expected to operate for approximately 90 days.

The second location will be selected in an area generally downwind from the EWS facility and is also expected to operate for approximately 90 days. When this site is finally selected and approved, the street address and location will be updated to this document.

Methods of Sampling to be Employed

An AreaRAE sampler equipped with an ammonia electro-chemical sensing cartridge will be used to collect air samples on a 60 second interval basis.  This sampler will operate for 90 days once properly calibrated and installed on site.  A Radillio passive air sampler will be used to collect samples which will subsequently be analyzed in a laboratory for ammonia.  Sampler will be operated on a random 1-in-6-day schedule.  These sampling devices will collect a sample for 24 hours generally from noon to noon of the next day.  A meteorological monitoring sensor array equipped to measure wind speed and direction will also be deployed at the site.

Data Reporting and Results

Preliminary data collected from both the AreaRAE ammonia monitor and Radillio passive ammonia sampler will be periodically posted to the TDEC web site for public evaluation.  The AreaRAE sampling data is expected to be made available approximately once each week and will be provided in the form of a trend graph and possibly a data table.

The Radillio passive sampler data will also be posted in a trend graph format after evaluation once it received from the support laboratory responsible for sample analysis and reporting.

Information About Ammonia in the Ambient Air

The State of Tennessee and the US Environmental Protection Agency do not have any ambient air quality standards for ambient ammonia (that is ammonia in the air outside of buildings).  The Tennessee Department of Labor (TOSHA) does regulate workplace exposures of employee’s to ammonia but not in the ambient air. The following Tennessee Department of Health web site is provided for additional health related information as to the effects ammonia may have on the general population. View the Deptmartment of Health site.

For More Information about this Study

Please submit your questions or comments to ask.tdec@tn.gov.