RE: Quarterly Inspection; AFIN ; Permit Number 0307-S4

Transcription

1 Document ID # August 15, 2012 The Honorable Keith Neely Bradley County Judge Bradley County Courthouse 101 East Cedar Warren, AR RE: Quarterly Inspection; AFIN ; Permit Number 0307-S4 Dear Judge Neely: On August 9, 2012, I conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at (501) or stringer@adeq.state.ar.us. Sincerely, Charles Stringer, ADEQ Inspector Solid Waste Management Division Attachment CC: Bryan Leamons, Engineer Supervisor, Solid Waste Management Division Maria Matoska, Engineer, Solid Waste Management Division

2 Arkansas Department of Environmental Quality Solid Waste Management Division Class 4 Landfill Inspection Site Name Bradley County Class 4 Landfill County Bradley AFIN Facility Address 1424 Bradley 25 North Phone Number Permit Number 0307-S4 Permittee Address 101 East Cedar Warren, AR Address PDS # Date Entry Time 10:55 Exit Time 13:00 X Depicts Violation Regulation 22 Operational Standards Category 1 R Repeat Violation Regulation Item Description Comments 607(l) Adequate employee facilities X 617(a)(b) Record keeping meets requirements specified by regulations See Category 1 Comment page X 613 Access requirements See Category 1 Comment page 607(j) Adequate provisions for backup equipment 617(c) Waste receipt records, ticket system maintained 607(k) Telephone system & written emergency response plan on site R 619(a) Annual compliance inspection by registered professional engineer See Category 1 Comment page X 618 Facility implements operating plan and narrative See Category 1 Comment page 701 Special waste disposal and procedures records X R Depicts Violation Category 2 Repeat Violation Regulation Item Description Comments X 607(a) Operations in accordance with permit documents See Category 2 Comment page 613(c) Adequate all weather operational roads 607(c)(d) Smallest practical area, single working face 607(e) Salvage operations meet approved conditions 607(f)(1) Scavenging of waste prohibited 613 (c) Proper wet weather repairs 607(b) Operations by licensed on-site personnel at all times 607(d) Waste spread and compacted as unloaded 607(g) Litter control provisions maintained 610(a) Disease vectors controlled 611 Gas monitoring program 622 Survey controls

3 X Regulation Item Description (h) )(1) 614( a) Surface water controls Contouring prevents surface water flowing into or through waste Run-on/off control system present and adequatee 607(h) )(2) Surface water control prevents off-site sediment accumulation 607(h)( (i)(o) Adequatee maintenance of intermediate/final cover vegetation 607(o) Leachate leaks or evidence of leachate seepage 6166 Liquid restrictions Category 2 (contin ued) See Category 2 Comment page Comments X R Depicts Violation (Repeat Violation) Regulation Item Description Category 3 Comments 608 Implementation of hazardous waste exclusion plan 609( a) Satisfactory weekly or more frequent cover 609(b) Satisfactory immediate cover 612(b),607(f)(4) 615 Cause discharge/leachate discharge leaving landfill 607(f)(3),615(a)(4) 607(o) Erosion or other cover defects resulting in exposed refuse 309(c ) Open burning prohibited Depositing waste in standing water prohibited Overfill/off lined area 617(a)(4), 621(e) (a)(4) (c ) 623 Regulation 22 - Records Date of last groundwater monitoring report Date of last engineering report Liner construction in progress 10/11/20100 Yes/No No Notice of liner construction Yes/No Date of last random inspection for unauthorized waste Date of last quarterly methane monitoring Date of last special waste received Previous quarter waste received 8/8/ nd Qt Total # for month Detection level Disposal location Tons Surface water DMR records current Yes/No No No storm water permit noted in records or at site. Third part CQA on-site during construction 611 Explosive gas records current? Yes/No Yes/No Operator Name & Number Paula Herring Signature of Inspector Exit Interview Conducted with Paula Herring Method On site Date Time 12:30 Class 4 Form 7/1/2012 For ADEQ Use Only

4 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Bradley County Class 4 Landfill AFIN Category 1 Comments Permit Number 0307-S4 Reg Recordkeeping Requirements (Record keeping meets requirements specified by regulations) (a) Requirements - The owner or operator must record and retain at the facility in an operating record or in an alternative location approved by the Director the following information as it becomes available: a (4) Any quality assurance/quality control (QA/QC) documentation, certification, and test result relating to the construction of the landfilll liner, ground water monitoring system if applicable, and final cover system; facility is not maintaining records of quality assurance/quality control (QA/QC) documentation, certification, and test result relating to the construction of the landfill liner. Reg Access Requirements (Access requirements) (b) Access Control and Signage - The site shall be adequately fenced with an entrance gate that can be locked. Class 4 landfills shall provide a sign showing the name of the facility, permit number, emergency telephone number, opening and closing hours and days of operation posted at the entrance to the facility. facility does not have a sign posted at the entrance gate that contains the required information listed above. The signs at the gate are for the onsite transfer station with no mention m of the Class 4 landfill. See Photo 1. Reg Annual Engineering Inspection Reports (Annual compliance inspection by registered professional engineer) (b) Report Requirements - A professional engineer registered in the State of Arkansas shall inspect the landfill site at least annually and prepare an annual report addressing operational compliance with w permit conditions, permit plans, specifications and the narrative and all applicable regulations. The Annual Engineering Inspection Report shall address the 12-month period from January through December and shall be submitted to ADEQ by June 30 of the following year. facility has not submitted an AEIR for the 2010 or 2011 calendar year. According to ADEQ records for the Facility s last AEIR was submitted 10/11/20100 for 2009 calendar year. The AEIR for the 2011 calendar year was due by June 30, Reg Operating Plan and Narrative (Plans and Narrative updated to reflect current operation) (c) Updates - Each facility shall update the plan and narrative as required to reflect current operations and regulations. Revisions to the document shall be submitted to the Department which reservess the right to requiree that the changes be accomplished through a permit modification prior to implementation. facility s current Operating Plan does not reflect the actual current operation and regulations. The most recent Operating Plan was submitted to the Department on 6/17/2003 (ADEQ XREF 20215) and needs to be revised. Date 8/ /9/2012 Signature of Inspector Page 3 Category 1 Comments Page7/1/2012 For ADEQ Use Only

5 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Bradley County Class 4 Landfill AFIN Category 2 Comments Permit Number 0307-S4 Reg General Operating Requirements (Operations in accordance with permit documents) (a) Conformance with Permit Documents - All operations at the landfill shalll be in accordance with the permit, approved plans and operating plan and narrative and all other applicable regulations. facility does not have adequate documentation concerning QA/QC tests have been performed during the construction of each cell and prior to placing waste in each cell, as described in the approved Design Criteria Document contained in ADEQ XREF Doc # The Departmentt has only received QA/QC test results for Cell 1. The facility is currently operating in Cell 9. The facility had documentation of QA/QC testing for another cell at the site; however, it was not able to be determined which cell the testing took place in. Additionally, a sedimentation/ /stormwater pond has been constructed near the southeastern corner of the landfill, which was not on the approved site plans nor is it within the permitted site boundary. Finally, the facility does not have the NPDES stormwater discharge permits as required in condition 17 of the General Conditions section of their permit. Reg General Operating Requirements (Surface water control prevents off-site sediment accumulation) (h) Additional Surface Water Controls and Best Management Practices - In conjunction with and in addition to the requirements of Reg and Reg , the owner or operator shall: (2) Install, construct, repair and maintain controls to prevent off-site sediment accumulation at all landfill, soil stockpile, and borrow site areas. Temporary and permanent seeding, grading, diking, terracing, diversion ditches, silt fencing, silt traps, vegetation filter strips, mulching, erosion control blankets and matting, gravel filter berms, checkk dams, riprap, sediment ponds and other best management practices for erosion and sediment control shall be provided as necessary. Best management practices for the site shall be in accordance with any stormwater permit issued for the site, shall be described in thee operating narrative, and shall be included in the permit plans as appropriate. sedimentation/stormwater pond near the southeastern corner of the landfill contains large amounts of sediment and requires maintenance. Additionally, the pond is not within the permitted landfill footprint. See photos 2 through 5. Date 8/ /9/12 Signature of Inspector Page 4 Category 2 Comments Page7/1/2012 For ADEQ Use Only

6 Permit # 0307-S4 Photo 1

7 Permit # 0307-S4 Photos 2 & 3

8 Permit # 0307-S4 Photos 4 & 5

9 Permit # 0307-S4 Photos 6 & 7