cc: Charles M. Johnson, Senior Manager, Regulated Waste Operations, Office of Land Resources

Transcription

1 July 31, 2018 Mike Vernon Russellville Yard Waste Facility 203 South Commerce Ave. Russellville, AR RE: Quarterly Inspection conducted on 7/10/2018 AFIN Permit Number 0053-SCYW Dear Mr. Vernon: The Arkansas Department of Environmental Quality Office of Land Resources (ADEQ) conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Act (Arkansas Code, Annotated, et seq.), of 1971, as amended, the Arkansas Pollution Control & Ecology Commission Regulation 22 (Solid Waste Management), and the above-referenced permit. The inspection identified conditions at your facility which the ADEQ alleges constitute violations of APC&EC Regulation No. 22. A copy of the inspection report is attached. 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 within thirty (30) calendar days from the date of this letter to the attention of Kim Davenport. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and persistent may warrant formal enforcement action. If you have any questions regarding the alleged violations, please do not hesitate to contact me at (501) or jason.gilkey@adeq.state.ar.us. Sincerely, Jason Gilkey Solid Office of Land Resources Attachment cc: Charles M. Johnson, Senior Manager, Regulated Waste Operations, Office of Land Resources ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS TELEPHONE / FAX /

2 Arkansas Department of Environmental Quality Office of Land Resources/Solid Waste Management Compost Inspection Site Name Russellville Yard Waste Facility County Pope AFIN Facility Address 3115 S. Mobile Ave., Russellville, AR Phone number Permit number 0053-SCYW Permittee Address S. Commerce Ave., Russellville, AR Address PDS # Date 7/10/2018 Entry time 1120 Exit time 1205 Classification Type Y Y Yard Waste O Source Separated Organic Waste S Mixed Solid Waste Regulation 22 Operational Standards Category 1 Regulation Item Description Comments 806(a)(4);(b)(9) Site access, all-weather roads, signage 808(a)(b)(c) 805(b)(1);805(c)(5) 808(a)(4);(b)(2) 805(b)(2);(c)(6) Record keeping and Reporting Operating records retained Type and source of incoming waste; monitoring quantity Conform to operations narrative/plan X 804 Adequate plans for monitoring, sampling, testing, contingency See Category 1 Comment Page 805(b)(1);(c)(5) Facility has operating plan Category 2 Regulation Item Description Comments X 805 Operations in accordance with permit documents See Category 2 Comment Page 805(c)(3) Type O&S Processing of incoming waste within 3 days 806(a)(5);(b)(10) 806(a)(5);(b)(10) 805(a)(2) 807(a)(b)(c);808(b)(9) Type O&S 805(c)(2) Type O&S 805(c)(4) Type O&S 806(a)(6);(b)(11) Adequate methods to manage odors Adequate controls to manage vectors, dust, and litter Operations follow acceptable methods Testing of run-off and compost Daily temperature readings recorded Finished compost not sold within 6 months Methods to handle and remove unacceptable waste X 806(a)(2);806(b)(3) Adequate composting area surface, slope and drainage See Category 2 Comment Page 805(a)(3) Operations performed by licensed operator 808(a)(4);(b)(2) Monitoring types of wastes received

3 Category 3 Regulation Item Description Comments 809(a)(b)(c) 805(c)(1) Type O&S 805(a)(1) 806(a)(3);(b)(7) 805(c)(3) Type O&S 806(b)(8) Type O&S Compost Utilization Compost process meets PFRP Operations preclude pollution Adequate controls for storm water, runoff, and NPDES Adequate leachate and NPDES control measures Leachate collection and removal system Regulation 22 - Records 804(b)(8)(i)(C)(D) Date of last random inspection for unauthorized hazardous waste Each load/daily Total number for month N/A 808(b)(11) Date of last quarterly/semi-annual/annual report 1/8/2018 Site Conditions Dry 808(a)(4)(b)(2) Last months reported waste received June 2018 = 602 Cubic Yards Weather Conditions Sunny Operator Name & Number Mike Vernon Signature of Inspector Exit Interview Conducted with Mike Vernon Method In-person Date 7/10/2018 Time 1155 Compost Form (Revised and Implemented 10/21/14) For ADEQ Use Only

4 Arkansas Department of Environmental Quality Office of Land Resources-Solid Waste Management Comments Page Site Name Russellville Yard Waste Facility AFIN Permit Number SCYW Category 1 Comments VI. CONDITIONS FOR TYPE Y COMPOSTING GENERAL PERMIT Permit Condition I. The facility shall develop and implement contingency plans in the approved operating plan for the following items: (a) The plan shall provide methods for controlling the of waste received at the facility and for removing and recovering non-compostable materials for recycling or disposal including the removal, storage, and disposal of any hazardous or unauthorized wastes; (b) The plan shall provide that firefighting equipment is available at the site and ensure that personnel have been trained in firefighting procedures. Where possible, the facility shall assure that fire protection services are available to the site through notification to local fire protection officials; (c) The plan shall provide remedial and contingency measures in the case that unapproved wastes are delivered to the facility or in the event of odors, equipment breakdown, and other emergency or undesirable conditions such as fire, dust, and vectors (d) The plan shall provide any necessary safety equipment that may be necessary due to site operations. Comment: The facility s contingency plan does not address Permit Condition I. (Refer to attached contingency plan provided by the facility.) Date 7/20/2018 Signature of Inspector Page 1 Category 1 Comments Page7/1/2012 For ADEQ Use Only

5 Arkansas Department of Environmental Quality Office of Land Resources-Solid Waste Management Comments Page Site Name Russellville Yard Waste Facility AFIN Permit Number SCYW Category 2 Comments Permit No. 0053_SCYW VI. CONDITIONS FOR TYPE Y COMPOSTING GENERAL PERMIT Permit Condition E. The facility shall be in compliance with the following location restrictions: 4. Composting areas or areas used for storing incoming materials or finished compost shall not be located within the following setback distances: a. Fifty feet (50 ) of the property boundary; Comment: Composting pile is less than 50 from property boundary. (Refer to Photos #3 & #4.) Reg Applicability And Exemptions (b) Acceptable Compostable Waste: (1) Yard waste and other vegetative materials such as grass clippings, leaves, and shredded or chipped brush, and tree pruning. Comment: Construction and demolition waste (painted lumber) and black plastic trash bags were observed in the compost pile. (Refer to Photos #5 & #6.) Reg Design Requirements (Adequate composting area surface, slope and drainage) (a) Class Y facility design must include the following: (2) The composting area shall have a surface that can withstand heavy equipment loads, and shall be sloped to prevent ponding. Comment: Ponding was observed in damaged areas of the composting surface. (Refer to Photo #7 & #8.) Date 7/20/2018 Signature of Inspector Page 1 Category 2 Comments Page7/1/2012 For ADEQ Use Only

6 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 1 Of 8 Date 7/10/2018 Time 1126 Description View of the compost pile, looking east. Photo # 2 Of 8 Date 7/10/2018 Time 1127 Description View of the compost pile and wind row, looking east.

7 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 3 Of 8 Date 7/10/2018 Time 1127 Description View of back side of the compost pile from Photo #2. The compost pile is less than 50 from the property boundary. Photo # 4 Of 8 Date 7/10/2018 Time 1128 Another angle taken from the location of Photo #3. The compost pile is less than 50 from the Description property boundary.

8 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 5 Of 8 Date 7/10/2018 Time 1134 Description Construction and demolition waste mixed in with the compostable yard waste. Photo # 6 Of 8 Date 7/10/2018 Time 1129 View of black plastic trash bags amid biodegradable bags located in the compostable yard Description waste.

9 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 7 Of 8 Date 7/10/2018 Time 1127 Description View of ponding water observed in wind row. Photo # 8 Of 8 Date 7/10/2018 Time 1128 Description View of ponding water in wind row.

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11 Date: 7/30/2018 Regulated Waste Operations Compliance Branch OFFICE OF LAND RESOURCES ROUTING SLIP Subj: Russellville Yard Waste Facility 0053-SCYW Q Inspection Report From: Route in turn to: Action Needed Date Received Date Reviewed Initials Ryan Hayden Concurrence Review 7/30/18 7/30/18 Chris Krou Concurrence Review 7/31/18 7/31/18 *Note: Marking the Concurrence box indicates the individual agrees with the applicable text as it relates to their individual discipline and Work Section (e.g., Engineer; Risk Assessor; Geology; Compliance; Policy/Management), as applicable. Marking the Review box indicates the individual has read the document. COMMENTS: cc: Annette Cusher, Jay Rich final report copy of.pdf

12 ~;~ RusseUVIUe ~ARKANSAS Mike Vernon Director of Animal Control August 6, 2018 Mr. Jason Gilkey, Solid Office of Land Resources Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas AFIN: _...:: 1:)~,~ - 0~\)::---:""1:-o:~,..:;.\-:-r-- PMT#:.Joo.bL5:oL.ii1~.CS.uC,""'I.L.&\N..- AUG RE : Quarterly Inspection: AFIN ; Permit Number 0053-SCYW Dear Mr. Gilkey; I received your letter from the inspection you performed on July 10,.,2018. The issues that were deemed uncompliant have been addressed as follows: :, Mulch pile within 50 feet of property boundary: We are currently working to be in compliance with this issue. Contigency Plan: We are currently working on a more detailed plan and will have it available in the near future. C and D waste in pile: Removed Ponding: corrected I believe I have adequately addressed the noted violations. Should you have any questions, please call me at my office. Sincerely, ~~ Mike Vernon, Director of Animal Control City of Russellville cc: Mayor Randy Horton, City of Russellville 3115 S. Mobile Russellville, AR The Natural Choice, In The Natural State!