Quarterly Inspection; AFIN ; Permit Number 0002-SWTP-R2

Transcription

1 Document ID September 29, 2015 Mr. Roger Davis Davis Rubber 1600 East 15th St. Little Rock, Arkansas RE: Quarterly Inspection; AFIN ; Permit Number 0002-SWTP-R2 Dear Mr. Davis: On September 25, 2015, 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 or stringer@adeq.state.ar.us. Sincerely, Charles Stringer ADEQ Inspector Solid Waste Management Division Attachment Revised

2 Arkansas Department of Environmental Quality Solid Waste Management Division Waste Tire Processing Facility Inspection Site Name Davis Rubber Co. County Pulaski AFIN Facility Address 1600 E. 15th St. Phone Number Permit Number 0002-SWTP-R2 Permittee Address P.O. Box 3773, Little Rock, AR Address PDS # Date 9/25/2015 Entry Time 1345 Exit Time 1450 Regulation 14 Operational Standards Category 1 Regulation Item Description Comments 1402(F) Sign posted with required information 1402(B) Waste tires stored separately from used tires 1207 Records maintained and available 1402(N) Emergency preparedness manual on site and updated 1210; 1402(L) Communication equipment maintained on site 1402(O) Department notified of emergency Category 2 Regulation Item Description Comments 1201 Operations in accordance with permit documents 1402(M) Site kept free of vegetation 901 Residuals disposed or recycled 1209; 1402(E) Mosquito and rodent control 1402(H) Passable access roads at all times 1402(J) Site bermed for runoff control 1402(I) Access to site controlled Category 3 Regulation Item Description Comments X 1402(R) Separation distances maintained See Category 3 Comments Page X 1402(C) Waste tire pile within maximum dimensions See Category 3 Comments Page 1204 Processed tires meet storage criteria 1402(K) Fire protection services assured 1402(G) Operations involving use of open flames prohibited X 1402(D) Fifty foot wide fire lanes and unobstructed See Category 3 Comments Page

3 1402(N) 1402(Q) 1402(Q) 1402(Q) 1215 Regulat Date of last revision/update to emergency preparedness manual Quantity of waste tires/processed tires received Quantity of waste tires stored on site Quantity of waste tires shipped from site Date of last annual report tion 14 - Records 7/ /13/2015 Site Conditions Weather Conditions Dry Sunny Operator Name & Number Roger Davis Signature of Inspector Exit Interview Conducted with Roger Davis Method On-Site Date 9/25/2015 Time 1440 WTP Form 7/1/2012 (Revised and Implemented 10/21/2014) For ADEQ Use Only

4 Arkansas Department of Environmental l Quality Solid Waste Management Division Comments Page Site Name Davis Rubber Co. AFIN Permit Number 0002-SWTP-R2 Category 3 Comments Reg Outdoor Above-Ground Tire Storage (Separation distances maintained) All waste tire sites, collection centers, and any processing or disposal facilities which store used tires, waste tires, or processed tires outdoors above ground must comply with the following technical and operational standards: (R) The minimum separations distances between exposed buildings and piles or between isolated piles shall be in accordance with National Fire Protection Association Standards. Comment: There is no separation between tire piles, shredded piles, and the shredder building near the front of the site. Tires were piled against the building wall and shredded tire material was intermingled with waste tires in this area. Seep photos 1 & 2 Reg Outdoor Above-Ground Tire Storage (Waste tire pile within maximum dimensions) All waste tire sites, collection centers, and any processing or disposal facilities which store used tires, waste tires, or processed tires outdoors above ground must comply with the following technical and operational standards: (C) An outdoor waste tire pile or processed tire pile shall have no greater than the following maximum dimensions: (1) Width: fifty feet (50 ); (2) Length: one hundred feet (100 ); and (3) Height: fifteen feet (15 ). Comment: The largest processed tire pile exceeds the 15 foot height limit. See photos 1 & 2. Reg Outdoor Above-Ground Tire Storage (Fifty foot wide fire lanes and unobstructed) All waste tire sites, collection centers, and any processing or disposal facilities which store used tires, waste tires, or processed tires outdoors above ground must comply with the following technical and operational standards: (D) A fifty-foot wide fire lane shall be placed around the perimeter of each waste tire pile. Accesss to the fire lane for emergency vehicles must be unobstructed at all times. Comment: Fire lanes are less than 50 feet wide and have truck tires stored on them which would limit access for emergency vehicles. See photo 3. Additional Comments Comment: No processing is occurring at this facility at this time. The facility is primarily being used as storage and according to Roger Davis will be used for processing when maintenance is occurring on the shredders at the new location. Comment: This facility has approximately 10% of the total number of waste tires noted during the previous inspection stored on site. According to the records provided, no tires were accepted at this facility during the month of August. Date 9/ /25/2015 Signature of Inspector Page 4 AdditionalComments Page7/1/2012 For ADEQ Use Only

5 Permit# 0002-SWTP-R2 Photo 1 & 2

6 Permit# 0002-SWTP-R2 Photo 3