2008 ANNUAL ENGINEERING INSPECTION REPORT

Transcription

1 2008 ANNUAL ENGINEERING INSPECTION REPORT EMS Class 3T Landfill Permit #0269-S3T-R1 PREPARED FOR: Eaton-Moery Environmental Services 1784 Hwy. 1 North Wynne, Arkansas PREPARED BY: Fields & Associates, LLC 75 Norfork Drive Maumelle, Arkansas June 2009

2 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report TABLE OF CONTENTS PROFESSIONAL ENGINEER S CERTIFICATION 1.0 INTRODUCTION BACKGROUND PURPOSE,SCOPE,AND APPLICABILITY FILL PROGRESSION AND LANDFILL UTILIZATION WASTE RECEIVED DURING THE REPORTING PERIOD REMAINING CAPACITY ESTIMATES REMAINING SITE LIFE LANDFILL OPERATIONS COMPLIANCE OF FILL PROGRESSION WITH PERMIT COMPLIANCE WITH REGULATION 22 AND PERMIT CONDITIONS Intermediate Cover Changes in Operation Plan Leachate Management Stormwater Management Hazardous Waste Exclusion Explosive Gas Monitoring Groundwater Monitoring Status of Remedial and Corrective Actions Closure Activities Closure and Post Closure Cost Estimates Other Items Impacting Compliance... 7 FIGURES FIGURE 1 SITE LOCATION MAP TABLES TABLE 1 ADEQ INSPECTION REPORT SUMMARY APPENDICES APPENDIX A APPENDIX B APPENDIX C APPENDIX D SOLID WASTE PERMIT #0269-S3T-R1 TOPOGRAPHIC SURVEY DRAWING ADEQ INSPECTION REPORTS CLOSURE AND POST-CLOSURE COST ESTIMATES Fields & Associates Project No i June, 2009

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4 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report 1.0 INTRODUCTION 1.1 BACKGROUND The Eaton-Moery Environmental Services (EMS) owns and operates a solid waste disposal facility (Facility) in Cross County, Arkansas in accordance with Permit # S3T-R1 (APPENDIX A). The general location of the Facility is shown on FIGURE 1. FIGURE 1: SITE LOCATION MAP 1.2 PURPOSE, SCOPE, AND APPLICABILITY Arkansas Regulation 22 (effective date February 24 th, 2006) requires permitted Class 3 landfills to submit Annual Engineering Inspection Reports to comply with Reg (a). More specifically, the regulation requires the following: Report Requirements - A professional engineer registered in the State of Arkansas shall inspect each permitted Class 3 facility and prepare a report addressing operational compliance with permit conditions, permit plans, Fields & Associates Project No June, 2009

5 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report specifications, the operating 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 th of the following year The Annual Engineering Inspection Report shall contain at a minimum: The volume capacity remaining in the current landfill cell or area and the projected date for opening new cells or areas; The estimated remaining volumetric capacity of all permitted Class 3 landfill units, the landfill capacity (total air space) utilized during the past one year period, and the estimated remaining site life (in years) based upon the utilization rate during the previous one (1) year period. Documentation of compliance of facility fill progression with the approved permit plans, specifications and operating narrative; Documentation of compliance with the operating requirements of this regulation and permit conditions and the approved operating plan; An updated contour map that depicts: o The horizontal and vertical extent of the active and inactive fill areas; o The status of each permitted landfill unit or cell (future unit, active unit, inactive, under construction, under interim cover, undergoing closure, closed, post-closure, ect.); o The survey grid system required by Reg ; o The location of any visible surface features or improvements such as roads, fences, buildings, gas control systems, surface water control systems, etcetera; and o The person responsible for gathering survey data and the date(s) that survey data was taken to prepare the map. For purposes of annual reports, survey data may be collected by any person familiar with survey techniques, however, a professional land surveyor, registered in the State of Arkansas, shall perform the initial survey of new units required under Reg (h) and final survey of closed units required under Reg.1301(i). Quantity location and characteristics of leachate collected, recirculated and disposed of; Maintenance of stormwater controls and other best management practices for erosion control; Status of capping and closure of completed areas; Status of remedial or corrective actions taken; Revised or updated facility Closure Plan and the Post-Closure Care Plan in accordance with the requirements contained in Chapter 13 Closure and the Post-Closure Care of these regulations. Updated Financial Assurance documentation as required in Chapter 14 Financial Assurance Criteria of these regulations; and Any other items that affect compliance at the landfill. Fields & Associates Project No June, 2009

6 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report The following document has been prepared to document compliance with the Facility s solid waste permit, permit plans, specifications, narrative and Arkansas Regulation 22. Fields & Associates Project No June, 2009

7 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report 2.0 FILL PROGRESSION AND LANDFILL UTILIZATION The Facility site consists of approximately acres with approximately acres of permitted landfill area for the tire monofill. The site also includes a Class 3C landfill, a waste tire processing facility and a transfer station. The Facility is designed to be developed with eleven waste disposal cells (Unit M1- Unit M11). The Facility is presently disposing in an area that is below the permitted grade in Unit M2/M-8. It appears from the CQA reports and from other site information that the eastern edge of M-8 was constructed at the time of M-2 (ADEQ Document Identifier Number 9451 and 15627), It should be noted that as built drawings were not included with the CQA reports. Presently units M-5-M-8 remain to be constructed. The area presently being filled has approximately 3,741 cubic yards of air space remaining. Unit M-8 will require construction this summer. 2.1 WASTE RECEIVED DURING THE REPORTING PERIOD The Facility reported for the period (January 1 st through December 31 st ) a total of 3, tons of tires were disposed at the Facility. The Facility s waste acceptance rate has dramatically decreased with the change in regulations that prohibit whole passenger tires from being disposed in a landfill. EMS is currently only taking truck and specialty tires. 2.2 REMAINING CAPACITY ESTIMATES DeClerk-Throesch Engineering and Land Surveying and Fields & Associates, LLC performed topographic surveys of the Facility and volume estimates of the air space utilized during the reporting period. The Facility utilized a total of 5,761 cubic yards of airspace from June 25, 2008 through June 26, The remaining gross capacity of the facility is estimated to be 181,443 cubic yards. It should be noted that this volume does not include the 112,000 cubic yards of overfill that was identified in the 2007 AEIR for the Facility. 2.3 REMAINING SITE LIFE Based on the utilization rate for the period June 25, 2008 through June 26, 2000 (5,761 cubic yards per year), the estimated remaining permitted capacity of the site with the present design is 32.5 years. Fields & Associates Project No June, 2009

8 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report 3.0 LANDFILL OPERATIONS The following information addresses the operation of the Facility in relation to applicable Permit conditions and Arkansas Regulation 22 requirements. When applicable, compliance monitoring corresponds to the reporting period from January 1, 2008 to December 31, COMPLIANCE OF FILL PROGRESSION WITH PERMIT Based on visits to the site during the reporting period as well as a review of available survey information, the landfill was not being developed and constructed in accordance with Arkansas Regulation 22, site Special Permit Conditions Numbers of the Permit. APPENDIX A contains a copy of Permit # 0269-S3T-R1. This is evidenced by the fact the Facility has approximately 112,000 cubic yards of air space that is above permitted grades. Included in APPENDIX B is topographic survey of the Facility performed on June 26, COMPLIANCE WITH REGULATION 22 AND PERMIT CONDITIONS The Facility is inspected on a regular basis by the ADEQ for compliance with the regulations and the operating permit. The inspection reports and responses for the period are included in APPENDIX C. Deficiencies were noted on the reports corresponding to the inspection dates. Included in TABLE 1 is a summary of the ADEQ inspection reports for the Facility. TABLE 1: ADEQ INSPECTION REPORT SUMMARY Number of Inspection in Regulation 22- Operational Standards Violation (Four Total Inspections) Category 1 Operations by licensed on-site personnel at all times 510(b) 4 Category 2 Surface water control prevents off-site sediment accumulation 510(h)(2) 1 Category 3 Operations in accordance with permit documents 410(a) 4 Satisfactory Intermediate Cover 512(c) Intermediate Cover The Facility is required to cover the active working face of the Landfill with 12 inches of earthen material when the working face reaches the appropriate size (100 feet by 200 feet). Based on visits to the site and ADEQ inspection reports during the reporting period it appears that the application of intermediate cover was not in compliance with the permit requirements and Arkansas Regulation 22 on at least on occasion. Operational conditions have improved with the reduction in the waste acceptance rate. Fields & Associates Project No June, 2009

9 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report The Facility has been able to maintain the required working face dimensions and apply intermediate cover as necessary Changes in Operation Plan During this reporting period there were not any changes made to the operating plan Leachate Management Leachate is not collected from the Facility Stormwater Management Surface water ditches, diversion berms, and trapezoidal perimeter channels, are used to provide stormwater drainage and protection of the final cover system from erosional effects. The stormwater control system also incorporates a sedimentation basin to handle stormwater runoff from the existing landfill. The water discharged from the existing sedimentation pond is regulated by NPDES Permit ARG The NPDES Discharge Monitoring Reports were submitted to ADEQ during the reporting period in accordance with the permit requirements. The stormwater controls had not been fully constructed at the Facility during the reporting period. Additional temporary stormwater controls were constructed in 2009 to mitigate erosion and improve stormwater run-on and run-off control for the Facility Hazardous Waste Exclusion The Facility s operational narrative has provisions for random inspections of waste loads that arrive at the Landfill for hazardous materials and/or substances. This inspection program is required by Arkansas Regulation 22 and is a condition of Permit #0269-S3T- R1. Records for inspections for hazardous materials and/or substances are located in the Facility office Explosive Gas Monitoring The Facility is not required by the solid waste permit to monitor for explosive gas due to the inert nature of the waste tires Groundwater Monitoring The Facility is not required to perform groundwater monitoring. There is a groundwater monitoring system for the Class 3C which is located directly to the south of the Facility Status of Remedial and Corrective Actions The Facility completed the required remedial and corrective actions as outlined in the Consent Order within the required timeframes Closure Activities During the reporting period, there were no closure activities at the Facility. Fields & Associates Project No June, 2009

10 EMS Class 3C Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report Closure and Post Closure Cost Estimates Arkansas Regulation 22 includes specific requirements for solid waste landfills associated with closure, post-closure care, and associated financial assurance. Specifically, facilities are required to maintain sufficient financial assurance to cover the costs of closure and the post-closure care periods. The financial assurance cost estimates were updated and are provided in APPENDIX D Other Items Impacting Compliance There are areas within the Facility that have exceeded final permitted grades. An overfill management plan was submitted to the ADEQ. EMS is in the process of determining the best method for correcting the overfilled areas. The overfill management requested until October 9, 2009 to complete the removal activities. Fields & Associates Project No June, 2009

11 EMS Class 3T Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report APPENDIX A SOLID WASTE PERMIT #0269-S3T-R1 Fields & Associates Project No June, 2009

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18 EMS Class 3T Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report APPENDIX B TOPOGRAPHIC SURVEY DRAWING Fields & Associates Project No June, 2009

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20 EMS Class 3T Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report APPENDIX C SOLID WASTE INSPECTION REPORTS Fields & Associates Project No June, 2009

21 Document ID # insp February 22, 2008 Eaton-Morey Env. Services, Inc 1784 Hwy 1 North Wynne, AR RE: AFIN Permit Nbr S3T-R1 Dear Mr. Eaton: On February 20, 2008, I performed a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Reg. 22, and the above referenced permit. A copy of the inspection report is enclosed for your review. Refer to the report to note any allegations of deficiencies that require corrective action. Please send a written response to the corrective action taken. Failure to respond to this letter in writing shall be construed as an admission of any allegations contained therein. Any items noted that are neglected and persistent may warrant enforcement action. If I can be any further assistance, feel free to contact me at (870) or 1825 Grant Ave, Jonesboro, AR., Sincerely, George Turner, Inspector Solid Waste Division

22 Arkansas Department of Environmental Quality Solid Waste Management Division Class 3 Landfill Inspection Site Name Facility Address Permittee Address Date EMS-Inc Class 3 Landfill Hwy 64, east of Wynne, AR Eaton-Morey Env. Service, Inc Hwy 1 North, Wynne, AR Entry Time 11:00 County Telephone Number Address Exit Time Cross AFIN Off :40 Permit Number Follow-Up 269-S3T-R1 Ye s No Regulation 22 - Operational Standards First Violation: Score of 1 First Violation : Score of 3 Category 1 Second Violation: Score of 2 Category 3 Second Violation : Score of 6 Third Violation : Score of 4 Third Violation : Score of 12 Adequate employee facilities 510(l) 12 Operations in accordance with permit documents 510(a) Record keeping meets requirements specified by regulations 520(a)(b) Gas monitoring program 514 Feeding of farm or domestic animals prohibited 510(f)(2) Facility implements operating plan and narrative 521 Salvage operations meet approved conditions 510(e) Hazardous waste exclusion plan 511 Required facilities, fencing and information signs posted 516(b) Access confined to hours of operation 516(d) Satisfactory daily / alternative cover 512(a)(b) Open burning prohibited 515(b), 510(f)(4) Scavenging of waste prohibited 510(f)(1) Cause discharge 518 Proper wet weather repairs 510(o) Leachate disposal records 520(a)(4) 2 Operations by licensed on-site personnel at all times 510(b) Special waste disposal and procedures records 701, 520(a)(2) Waste spread and compacted as unloaded 510(d) Depositing waste in standing water prohibited 510(f)(3), 518(a)(4) Adequate all weather operational roads 516(c) Adequate provisions for backup equipment 510(j) Waste receipt records, ticket system maintained 520(c) Telephone system and written emergency response plan on site 510(k) Category 2 Adequate access control 516(a) First Violation: Score of 2 Second Violation: Score of 4 Third Violation : Score of 8 Smallest practical area, unloading supervised, single working face 510(c) Litter control provisions maintained 510(g) Disease vectors controlled 513(a) Contouring prevents surface water flowing into or through waste 510(h)(1) Plans and narrative updated to reflect current operation 521(c) Annual compliance inspection by registered professional engineer 522(a) Run-on/run-off control system present and adequate 517(a)(b) Surface water control prevents off-site sediment accumulation 510(h)(2) Landfill compliance with liquid restrictions 519 Adequate maintenance of final cover vegetation 510(i) See Page 2 Regulation 22 - Records Erosion or other cover defects resulting in exposed refuse 510(n) Leachate leaks or evidence of leachate seepage 510(n) Satisfactory intermediate cover 512(c) Leachate discharge leaving landfill 518(a)(5) Comments 0-16 Satisfactory Marginal >25 Unsatisfactory 520(a)(8), 204(b) Date of last groundwater monitoring report NA 522 Date of last engineering report 520(a)(8), 528(h) Date of last liner certification report NA 511 Date of last random inspection for hazardous waste NA Total # for month 514, 520(a)(3) Date of last quarterly methane monitoring NA Detection level 701, 520(a)(2) Date of last special waste received NA Disposal location 520(a)(4) Date of leachate disposal NA Method Location 520(c) Last months reported waste received Tons / Cy TOTAL SCORE NA -14- X Operator Name & Number Ken Thomas Signature of Inspector 1997 Class 3 Lf Form Revisions: FOR ADEQ USE ONLY 01/2003 / 08/19/2003 / 10/18/2005 / 01/30/2007 / 04/01/2007

23 Arkansas Department of Environmental Quality - Facility Evaluation Comments Page Name of Site: EMS-INC Tire Monofil Date: County: Cross AFIN/CSN# Permit# 269-S3T-R1 Category 1 Licensed operator. Comments: Ken Thomas is a new operator and is not licensed. Category 3 Permit Condition 20 Comments: There was only one layer of plastic present at the time of this inspection. In one portion of the cell there is no plastic present. Permit condition 20 states as follows: Prior to the placement of waste tires in the active area, the bottom clay liner shall be certified and covered with at least two(2) layers of 4-mil plastic sheeting, or approved equal. A minimum of two(2) feet overlap is required to join the separate units. The liner material shall be maintained in a flaw free condition or as close to flaw free as practically possible for that reason, small flaws in the plastic should not compromise the effectiveness of the plastic. However, large flaws could allow unneeded soil contamination of the tires and should be repaired by placing an additional two(2) layers of the plastic sheeting large enough in size to sufficiently cover and overlap the flawed area. The plastic cover shall also be applied over any soil layer wherever tires will be placed on that soil layer; i.e., over intermediate soil cover layers prior to the tire placement as the fill progresses vertically upward. Category 3 Permit Condition 21 Comments: The staging area exceeds the 20 requirement by hundreds of feet. Permit Condition 21 states; In-coming waste tire loads shall be unloaded in the staging area as close to the working face as safely possible, preventing unnecessary soil contamination that may be caused by pushing the waste tires long distances to the fill area. Generally, the edge of the staging area, closest to the active fill area, should be located no more than twenty(20) feet from the active fill area. The waste tires shall be placed in the fill area in a condition where they may be recovered at a later date for processing, reuse or recycling. Category 3 Permit Condition 22 Comments: The exposed tire mass in the fill area was greater than the dimensions allowed by the permit. The allowed size is 100 X200. At thee time of this inspection the fill area was approximately 200 X400. Permit Condition 22 also, states: A woven high density polyethylene liner shall be installed prior to the placement of any intermediate or final soil cover to prevent any additional soil contamination of the tires. The liner specifications shall meet or exceed those as presented for the material in Appendix B of the Design and Operational Narrative (CANVEX C94WB or approved equal). The synthetic liner shall be applied as the working face reaches the standard dimensions of the material. At this time the dimensions shall be forty(40) feet by one hundred(100) feet and may only be deviated from with prior Department approval. Separate units shall be joined as prescribed in Figure 4-1 Waste Tire Progression dated March 13, 1997 and submitted with the Design and Operational Narrative dated April 24, There is no (CANVWX C94WB) polyethylene liner present over the tires. The exposed tires should not exceed forty(40) feet by one hundred(100) feet. Category _3 Permit Condition 23 Comments: Since the working face was over its allowable size, Permit condition 23 was violated because the synthetic cover material had not been put in place and covered with one(1) foot of soil as soon as the working face reached the allowable size. Permit Condition 23 requires; As soon as the working face reaches the appropriate size and the synthetic is placed over the tires, a minimum of one(1) foot of compacted soil shall be placed over the synthetic cover material to within three(3) feet of the exposed vertical face of the fill area. This should prevent unnecessary soil contamination of the waste tires. One(1) foot of soil is required as soon as the working face reaches the appropriate size and the liner is in place. A portion of the fill did have synthetic cover material and the dirt covered over the plastic only. Dirt was not being dozed into the tires. There was an improvement over the last inspection

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30 Document ID # insp May 13, 2008 Eaton-Morey Env. Services, Inc 1784 Hwy 1 North Wynne, AR RE: AFIN Permit Nbr S3T-R1 Dear Mr. Eaton: On April 30, 2008, I performed a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Reg. 22, and the above referenced permit. A copy of the inspection report is enclosed for your review. Refer to the report to note any allegations of deficiencies that require corrective action. Please send a written response to the corrective action taken. Failure to respond to this letter in writing shall be construed as an admission of any allegations contained therein. Any items noted that are neglected and persistent may warrant enforcement action. If I can be any further assistance, feel free to contact me at (870) or 1825 Grant Ave, Jonesboro, AR., Sincerely, George Turner, Inspector Solid Waste Division

31 Arkansas Department of Environmental Quality Solid Waste Management Division Class 3 Landfill Inspection Site Name Facility Address Permittee Address Date EMS-Inc Class 3 Landfill Hwy 64, east of Wynne, AR Eaton-Morey Env. Service, Inc Hwy 1 North, Wynne, AR Entry Time 13:36 County Telephone Number Address Exit Time Cross AFIN Off :30 Permit Number Follow-Up 269-S3T-R1 Ye s No Regulation 22 - Operational Standards First Violation: Score of 1 First Violation : Score of 3 Category 1 Second Violation: Score of 2 Category 3 Second Violation : Score of 6 Third Violation : Score of 4 Third Violation : Score of 12 Adequate employee facilities 510(l) 12 Operations in accordance with permit documents 510(a) Record keeping meets requirements specified by regulations 520(a)(b) Gas monitoring program 514 Feeding of farm or domestic animals prohibited 510(f)(2) Facility implements operating plan and narrative 521 Salvage operations meet approved conditions 510(e) Hazardous waste exclusion plan 511 Required facilities, fencing and information signs posted 516(b) Access confined to hours of operation 516(d) Satisfactory daily / alternative cover 512(a)(b) Open burning prohibited 515(b), 510(f)(4) Scavenging of waste prohibited 510(f)(1) Cause discharge 518 Proper wet weather repairs 510(o) Leachate disposal records 520(a)(4) 2 Operations by licensed on-site personnel at all times 510(b) Special waste disposal and procedures records 701, 520(a)(2) Waste spread and compacted as unloaded 510(d) Depositing waste in standing water prohibited 510(f)(3), 518(a)(4) Adequate all weather operational roads 516(c) Adequate provisions for backup equipment 510(j) Waste receipt records, ticket system maintained 520(c) Telephone system and written emergency response plan on site 510(k) Category 2 Adequate access control 516(a) First Violation: Score of 2 Second Violation: Score of 4 Third Violation : Score of 8 Smallest practical area, unloading supervised, single working face 510(c) Litter control provisions maintained 510(g) Disease vectors controlled 513(a) Contouring prevents surface water flowing into or through waste 510(h)(1) Plans and narrative updated to reflect current operation 521(c) Annual compliance inspection by registered professional engineer 522(a) Run-on/run-off control system present and adequate 517(a)(b) Surface water control prevents off-site sediment accumulation 510(h)(2) Landfill compliance with liquid restrictions 519 Adequate maintenance of final cover vegetation 510(i) See Page 2 Regulation 22 - Records Erosion or other cover defects resulting in exposed refuse 510(n) Leachate leaks or evidence of leachate seepage 510(n) Satisfactory intermediate cover 512(c) Leachate discharge leaving landfill 518(a)(5) Comments 0-16 Satisfactory Marginal >25 Unsatisfactory 520(a)(8), 204(b) Date of last groundwater monitoring report NA 522 Date of last engineering report 520(a)(8), 528(h) Date of last liner certification report NA 511 Date of last random inspection for hazardous waste NA Total # for month 514, 520(a)(3) Date of last quarterly methane monitoring NA Detection level 701, 520(a)(2) Date of last special waste received NA Disposal location 520(a)(4) Date of leachate disposal NA Method Location 520(c) Last months reported waste received 495 Tons / Cy TOTAL SCORE NA -14- X Operator Name & Number Ken Thomas Signature of Inspector 1997 Class 3 Lf Form Revisions: FOR ADEQ USE ONLY 01/2003 / 08/19/2003 / 10/18/2005 / 01/30/2007 / 04/01/2007

32 Arkansas Department of Environmental Quality - Facility Evaluation Comments Page Name of Site: EMS-INC Tire Monofil Date: County: Cross AFIN/CSN# Permit# 269-S3T-R1 Category 1 Licensed operator. Comments: Ken Thomas is a new operator and is not licensed. Category 3 Permit Condition 20 Comments: There was only one layer of plastic present at the time of this inspection. In one portion of the cell there is no plastic present. Permit condition 20 states as follows: Prior to the placement of waste tires in the active area, the bottom clay liner shall be certified and covered with at least two(2) layers of 4-mil plastic sheeting, or approved equal. A minimum of two(2) feet overlap is required to join the separate units. The liner material shall be maintained in a flaw free condition or as close to flaw free as practically possible for that reason, small flaws in the plastic should not compromise the effectiveness of the plastic. However, large flaws could allow unneeded soil contamination of the tires and should be repaired by placing an additional two(2) layers of the plastic sheeting large enough in size to sufficiently cover and overlap the flawed area. The plastic cover shall also be applied over any soil layer wherever tires will be placed on that soil layer; i.e., over intermediate soil cover layers prior to the tire placement as the fill progresses vertically upward. Category 3 Permit Condition 21 Comments: The staging area exceeds the 20 requirement by hundreds of feet. Permit Condition 21 states; In-coming waste tire loads shall be unloaded in the staging area as close to the working face as safely possible, preventing unnecessary soil contamination that may be caused by pushing the waste tires long distances to the fill area. Generally, the edge of the staging area, closest to the active fill area, should be located no more than twenty(20) feet from the active fill area. The waste tires shall be placed in the fill area in a condition where they may be recovered at a later date for processing, reuse or recycling. Category 3 Permit Condition 22 Comments: The exposed tire mass in the fill area was greater than the dimensions allowed by the permit. The allowed size is 100 X200. At thee time of this inspection the fill area was approximately 200 X400. Permit Condition 22 also, states: A woven high density polyethylene liner shall be installed prior to the placement of any intermediate or final soil cover to prevent any additional soil contamination of the tires. The liner specifications shall meet or exceed those as presented for the material in Appendix B of the Design and Operational Narrative (CANVEX C94WB or approved equal). The synthetic liner shall be applied as the working face reaches the standard dimensions of the material. At this time the dimensions shall be forty(40) feet by one hundred(100) feet and may only be deviated from with prior Department approval. Separate units shall be joined as prescribed in Figure 4-1 Waste Tire Progression dated March 13, 1997 and submitted with the Design and Operational Narrative dated April 24, There is no (CANVWX C94WB) polyethylene liner present over the tires. The exposed tires should not exceed forty(40) feet by one hundred(100) feet. Category _3 Permit Condition 23 Comments: Since the working face was over its allowable size, Permit condition 23 was violated because the synthetic cover material had not been put in place and covered with one(1) foot of soil as soon as the working face reached the allowable size. Permit Condition 23 requires; As soon as the working face reaches the appropriate size and the synthetic is placed over the tires, a minimum of one(1) foot of compacted soil shall be placed over the synthetic cover material to within three(3) feet of the exposed vertical face of the fill area. This should prevent unnecessary soil contamination of the waste tires. One(1) foot of soil is required as soon as the working face reaches the appropriate size and the liner is in place. A portion of the fill did have synthetic cover material and the dirt covered over the plastic only. Dirt was not being dozed into the tires. There was an improvement over the last inspection

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39 Document ID # insp August 15, 2008 Eaton-Morey Env. Services, Inc 1784 Hwy 1 North Wynne, AR RE: AFIN Permit Nbr S3T-R1 Dear Mr. Eaton: On august 13, 2008, I performed a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Reg. 22, and the above referenced permit. A copy of the inspection report is enclosed for your review. Refer to the report to note any allegations of deficiencies that require corrective action. Please send a written response to the corrective action taken. Failure to respond to this letter in writing shall be construed as an admission of any allegations contained therein. Any items noted that are neglected and persistent may warrant enforcement action. If I can be any further assistance, feel free to contact me at (870) or 1825 Grant Ave, Jonesboro, AR., Sincerely, George Turner, Inspector Solid Waste Division

40 Arkansas Department of Environmental Quality Solid Waste Management Division Class 3 Landfill Inspection Site Name Facility Address Permittee Address Date EMS-Inc Class 3 Landfill Hwy 64, east of Wynne, AR Eaton-Morey Env. Service, Inc Hwy 1 North, Wynne, AR Entry Time 9:56 County Telephone Number Address Exit Time Cross AFIN Off :30 Permit Number Follow-Up 269-S3T-R1 Ye s No Regulation 22 - Operational Standards First Violation: Score of 1 First Violation : Score of 3 Category 1 Second Violation: Score of 2 Category 3 Second Violation : Score of 6 Third Violation : Score of 4 Third Violation : Score of 12 Adequate employee facilities 510(l) 12 Operations in accordance with permit documents 510(a) Record keeping meets requirements specified by regulations 520(a)(b) Gas monitoring program 514 Feeding of farm or domestic animals prohibited 510(f)(2) Facility implements operating plan and narrative 521 Salvage operations meet approved conditions 510(e) Hazardous waste exclusion plan 511 Required facilities, fencing and information signs posted 516(b) Access confined to hours of operation 516(d) Satisfactory daily / alternative cover 512(a)(b) Open burning prohibited 515(b), 510(f)(4) Scavenging of waste prohibited 510(f)(1) Cause discharge 518 Proper wet weather repairs 510(o) Leachate disposal records 520(a)(4) 2 Operations by licensed on-site personnel at all times 510(b) Special waste disposal and procedures records 701, 520(a)(2) Waste spread and compacted as unloaded 510(d) Depositing waste in standing water prohibited 510(f)(3), 518(a)(4) Adequate all weather operational roads 516(c) Adequate provisions for backup equipment 510(j) Waste receipt records, ticket system maintained 520(c) Telephone system and written emergency response plan on site 510(k) Category 2 Adequate access control 516(a) First Violation: Score of 2 Second Violation: Score of 4 Third Violation : Score of 8 Smallest practical area, unloading supervised, single working face 510(c) Litter control provisions maintained 510(g) Disease vectors controlled 513(a) Contouring prevents surface water flowing into or through waste 510(h)(1) Plans and narrative updated to reflect current operation 521(c) Annual compliance inspection by registered professional engineer 522(a) Run-on/run-off control system present and adequate 517(a)(b) Surface water control prevents off-site sediment accumulation 510(h)(2) Landfill compliance with liquid restrictions 519 Adequate maintenance of final cover vegetation 510(i) See Page 2 Regulation 22 - Records Erosion or other cover defects resulting in exposed refuse 510(n) Leachate leaks or evidence of leachate seepage 510(n) Satisfactory intermediate cover 512(c) Leachate discharge leaving landfill 518(a)(5) Comments 0-16 Satisfactory Marginal >25 Unsatisfactory 520(a)(8), 204(b) Date of last groundwater monitoring report NA 522 Date of last engineering report 520(a)(8), 528(h) Date of last liner certification report NA 511 Date of last random inspection for hazardous waste NA Total # for month 514, 520(a)(3) Date of last quarterly methane monitoring NA Detection level 701, 520(a)(2) Date of last special waste received NA Disposal location 520(a)(4) Date of leachate disposal NA Method Location 520(c) Last months reported waste received 13, 050 Tons / Cy May, June & July TOTAL SCORE NA -14- X Operator Name & Number Ken Thomas Signature of Inspector 1997 Class 3 Lf Form Revisions: FOR ADEQ USE ONLY 01/2003 / 08/19/2003 / 10/18/2005 / 01/30/2007 / 04/01/2007

41 Arkansas Department of Environmental Quality - Facility Evaluation Comments Page Name of Site: EMS-INC Tire Monofil Date: County: Cross AFIN/CSN# Permit# 269-S3T-R1 Note: There has been a significant improvement since the inspection of The working face and number of exposed tires is much less. The work is not however completed to meet complete compliance. Category 1 Licensed operator. Comments: Ken Thomas is a new operator and is not licensed. Category 3 Permit Condition 21 Comments: The staging area exceeds the 20 requirement. Permit Condition 21 states; In-coming waste tire loads shall be unloaded in the staging area as close to the working face as safely possible, preventing unnecessary soil contamination that may be caused by pushing the waste tires long distances to the fill area. Generally, the edge of the staging area, closest to the active fill area, should be located no more than twenty(20) feet from the active fill area. The waste tires shall be placed in the fill area in a condition where they may be recovered at a later date for processing, reuse or recycling. Category 3 Permit Condition 22 Comments: The exposed tire mass in the fill area was greater than the dimensions allowed by the permit. The allowed size is 100 X200. At thee time of this inspection the fill area was approximately 200 X200. Permit Condition 22 also, states: A woven high density polyethylene liner shall be installed prior to the placement of any intermediate or final soil cover to prevent any additional soil contamination of the tires. The liner specifications shall meet or exceed those as presented for the material in Appendix B of the Design and Operational Narrative (CANVEX C94WB or approved equal). The synthetic liner shall be applied as the working face reaches the standard dimensions of the material.

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48 Document ID # insp November 12, 2008 Eaton-Morey Env. Services, Inc 1784 Hwy 1 North Wynne, AR RE: AFIN Permit Nbr S3T-R1 Dear Mr. Eaton: On November 06, 2008, I performed a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Reg. 22, and the above referenced permit. A copy of the inspection report is enclosed for your review. Refer to the report to note any allegations of deficiencies that require corrective action. Please send a written response to the corrective action taken. Failure to respond to this letter in writing shall be construed as an admission of any allegations contained therein. Any items noted that are neglected and persistent may warrant enforcement action. If I can be any further assistance, feel free to contact me at (501) (office) or (501) (cell). Sincerely, Kenneth Burks, Inspector Solid Waste Management Division ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS / TELEPHONE / FAX

49 Arkansas Department of Environmental Quality Solid Waste Management Division Class 3 Landfill Inspection Site Name Facility Address Permittee Address Date 11/06/08 EMS-Inc Class 3 Monofill Hwy 64, east of Wynne, AR Eaton-Morey Env. Service, Inc. 1784; Hwy 1 North, Wynne, AR Entry Time 0830 County Telephone Number Address Exit Time Cross AFIN Off Permit Number Follow-Up 0269-S3T-R1 Ye s No x Regulation 22 - Operational Standards Category 1 First Violation: Score of 1 First Violation : Score of 3 Second Violation: Score of 2 Category 3 Second Violation : Score of 6 Third Violation : Score of 4 Third Violation : Score of 12 Adequate employee facilities 510(l) 12 Operations in accordance with permit documents 510(a) Record keeping meets requirements specified by regulations 520(a)(b) Gas monitoring program 514 Feeding of farm or domestic animals prohibited 510(f)(2) Facility implements operating plan and narrative 521 Salvage operations meet approved conditions 510(e) Hazardous waste exclusion plan 511 Required facilities, fencing and information signs posted 516(b) Satisfactory daily / alternative cover 512(a)(b) Access confined to hours of operation 516(d) Open burning prohibited 515(b), 510(f)(4) Scavenging of waste prohibited 510(f)(1) Cause discharge 518 Proper wet weather repairs 510(o) Leachate disposal records 520(a)(4) 4 Operations by licensed on-site personnel at all times 510(b) Special waste disposal and procedures records 701, 520(a)(2) Waste spread and compacted as unloaded 510(d) Depositing waste in standing water prohibited 510(f)(3), 518(a)(4) Adequate all weather operational roads 516(c) Erosion or other cover defects resulting in exposed refuse 510(n) Adequate provisions for backup equipment 510(j) Leachate leaks or evidence of leachate seepage 510(n) Waste receipt records, ticket system maintained 520(c) 3 Satisfactory intermediate cover 512(c) Telephone system and written emergency response plan on site 510(k) Leachate discharge leaving landfill 518(a)(5) First Violation: Score of 2 Category 2 Second Violation: Score of 4 Third Violation : Score of 8 Adequate access control 516(a) Smallest practical area, unloading supervised, single working face 510(c) Litter control provisions maintained 510(g) Disease vectors controlled 513(a) Contouring prevents surface water flowing into or through waste 510(h)(1) Plans and narrative updated to reflect current operation 521(c) Annual compliance inspection by registered professional engineer 522(a) Run-on/run-off control system present and adequate 517(a)(b) 2 Surface water control prevents off-site sediment accumulation 510(h)(2) Landfill compliance with liquid restrictions 519 Adequate maintenance of final cover vegetation 510(i) See Comments Page. Regulation 22 - Records Comments TOTAL SCORE 0-16 Satisfactory Marginal >25 Unsatisfactory (a)(8), 204(b) Date of last groundwater monitoring report 07/07/ Date of last engineering report 520(a)(8), 528(h) Date of last liner certification report 03/22/ Date of last random inspection for hazardous waste 10/28/08 Total # for month , 520(a)(3) Date of last quarterly methane monitoring 07/29/08 Detection level 0 701, 520(a)(2) Date of last special waste received Disposal location 520(a)(4) Date of leachate disposal NA Method Location 520(c) Last months reported waste received Tons / Cy October 07/01/08 Operator Name & Number Ken Thomas Signature of Inspector 1997 Class 3 Lf Form Revisions: FOR ADEQ USE ONLY 01/2003 / 08/19/2003 / 10/18/2005 / 01/30/2007 / 04/01/2007

50 Arkansas Department of Environmental Quality Solid Waste Management Division Comments Page Site Name EMS CLASS 3 MONOFILL AFIN Permit Number 0269-S3T-R1 Category 1 Comments Licensed Operator. Reg. 510(b) - Ken Thomas is the new operator at this facility and he is not licensed. Category 2 Comments Reg (h)(2) Surface water control prevents off site sediment accumulation: Stormwater controls for the Class III Monofill have not been fully constructed and are not in place at this time. Category 3 Comments Reg (c) Satisfactory intermediate cover: Exposed tires were noted in numerous areas of the landfill. Reg (a) Operations in accordance with permit documents: Permit Condition #1 The disposal facility shall be constructed, operated, and maintained in accordance with the final plans and specification as approved by the Department and in compliance with all practical provisions of the Act, Regulation #22, and all other applicable rules and regulations: Beginning August 08, 2008, Reg mandates that only automobile tires that have been processed by cutting, shredding, or splitting into sufficiently small parts, or processed by baling may be disposed of in a tire monofill: Automobile tires are being placed in the monofill without processing of any kind. Permit Condition #22 The exposed tire mass in the fill area was greater than the dimensions allowed by the permit: The allowed size is 100 x200. At the time of this inspection, the fill area was approximately 200 x200. Also, a synthetic liner shall be applied as the working face reaches the allowed limits. Signature of Inspector Inspection Date 11/06/08 Page 2 01/2003 Comments Form Revisions: FOR ADEQ USE ONLY 04/01/2007

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62 EMS Class 3T Landfill Solid Waste Permit # 0269-S3T-R Annual Engineering Inspection Report APPENDIX D CLOSURE AND POST-CLOSURE COST ESTIMATES Fields & Associates Project No June, 2009

63 Prepared By: Fields & Associates, LLC F&A Closure Cost Estimates Project: Eaton-Moery Environmental Services, Inc. (EMS) Class 3T Landfill ADEQ Solid Waste Permit 0269-S3T-R1 AFIN Subject: 2006 Closure care cost estimates per the requirements of Section (d) of ADEQ Regulation 22. Estimates based on total site closure area of 22.3 acres Item No. Item Description Unit Quantity Unit Cost Total Remarks 1 Control Grading Acre 22.3 $ $13, (Note 1) 2 Clay Cap Construction 2(a) Clay cap construction: Compacted clay layer Acre 22.3 $6, $144, Based on $2.67 per cubic yard at 2,420 cyd/acre (Note 2) 2(b) Quality Assurance/Quality Control Acre 22.3 $1, $23, (c) Synthetic (LLDPE Cover & QA/QC Acre 22.3 $0.00 $0.00 Not Applicable 2(d) Install Passive gas Vents No 0 $0.00 $0.00 Not Applicable 3 Placing top soil (on site material) Acre 22.3 $2, $51, Based on $2.85 per cyd at 807 cyd/acre (Note 3) 4 Seeding & Establishing vegetation Acre 22.3 $ $18, Remove Temporary Building L. Sum 0 $0.00 $0.00 Not Applicable 6 Remove Equipment L. Sum 0 $0.00 $0.00 Not Applicable 7 Surface Drainage Ditches Acre 0 $0.00 $ Replace Defective GW Monitoring Well L. Sum 0 $3, $ Plug & Abandon Defective GW Well L. Sum 0 $ $ Final Closure Topographic Survey Acre 0 $ $ Initial Final Closure Cost NA NA NA $250, Contingency NA NA NA $12, Based on 5% of Initial Closure Cost TOTAL NA NA NA $262, $267, % 1998 $271, % 1999 $275, % 2000 $280, % 2001 $286, % 2002 $290, % 2003 $295, % 2004 $302, % 2005 $313, % 2006 $322, % 2007 $331, % 2008 $344, % TOTAL CLOSURE COSTS $371, Note 1: RS Means (3rd Quarter 2007) Finish Grading Steep Slopes 0.15 per S.Y. The $ adjusted for inflation is equivalent to this value Note 2: RS Means (3rd quarter 2007) Sheepsfoot Roller six inch lift 4 passes $0.96 per E.C.Y. Note 3: RS Means (3rd quarter 2007) Common Earth 1500 foot haul $3.53.E.C.Y.. The $2.85 per cubic yard adjusted for inflation is equivalent to this value.

64 Prepared By: Fields & Associates, LLC F&A Post Closure Cost Estimates Project: Eaton-Moery Environmental Services, Inc. (EMS) Class 3T Landfill ADEQ Solid Waste Permit 0269-S3T-R1 AFIN Subject: Post-Closure care cost estimates Per Section of ADEQ Regulation 22. Estimates based on total site closure area of acres Item No. Item Description Unit Quantity Unit Cost Multiplier Years Total Remarks 1 Routine Inspection Acre 2 $ $2, ) Maintenance of on-site improvements L. Sum 1 $ $1, Maintaining vegetation Acre $ $15, Final Plugging of GW Monitoring Wells Well 0 $ $0.00 Not Applicable 5 Replacing Defective GW Monitoring Wells Well 0 $3, $0.00 Not Applicable 6 Plugging Defective GW Monitoring Wells Well 0 $ $0.00 Not Applicable 7 Methane Gas Monitoring Event/Yr 0 $ $0.00 Not Applicable 8 (a) GW Monitoring Wells Sampling & Analysis Event/Yr 0 $3, $0.00 Not Applicable 8 (b) GW Quality Statistical Analysis Event/Yr 0 $1, $0.00 Not Applicable 9 Surface Water Sampling & Analysis (NPDES) Event/Yr 0 $ $ Leachate System Maintenance Ft/yr 0 $ $0.00 Not Applicable 11 Leachate Management Gal/yr 0 $ $0.00 Not Applicable 12 Initial Final Closure Cost NA NA NA NA $18, Administrative NA NA NA NA $1, Based on 10% of Initial Closure Cost 14 Contingency NA NA NA NA $ Based on 5% of Initial Closure Cost TOTAL NA NA NA NA $21, $21, % 1998 $21, % 1999 $22, % 2000 $22, % 2001 $23, % 2002 $23, % 2003 $23, % 2004 $24, % 2005 $25, % 2006 $25, % 2007 $26, % 2008 $27, %

65 IMPLICIT PRICE DEFLATOR BASED ON U.S. GROSS NATIONAL PRODUCT (Updated March 31 of each year) Year Implicit Price Deflators (This Year/Last Year) Inflation Factor IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % IPD = IPD = % Retrived from the ADEQ Hazardous Waste Division Website on March 30, 2008 In 2004, the Bureau of Economic Analysis revised its indexing and set the baseline index at 100 for the year Previous implicit price deflators shown here (2003 and earlier) were based on a baseline index of 100 for the year Information in this table is obtained from the Federal Reserve Bank of St. Louis