March 18, 2020 Violation Notice - Improper Operation of Flares
EGLE issued Advanced Disposal Services (ADS) a Violation Notice dated March 18, 2020, alleging ADS had operated the two enclosed flares at temperatures which were lower than required by their permit at various times between Feb 14, 2019, and Nov 25, 2019. Emissions from the two enclosed flares were successfully tested in 2016 (i.e. - emissions were in compliance with permit requirements). Following a successful compliance test, the landfill is required to operate the flares at similar temperatures to those used during the compliance test. Apparently, ADS inadvertently used a lower temperature set point and operated the flares at lower than required temperatures for a significant period of time.
ADS supplied a very detailed response explaining that although the flares were operating at all times the setpoint combustion temperature was lower than required. After reviewing the Violation Notice and ADS’ response, The Conservancy Initiative does not believe operating the flares at a slightly lower temperature posed a significant impact on the environment. What is alarming is the problem was allowed to continue for so long.