Maryland Department of Environment Water Management Administration Program 1800 Washington Blvd, Baltimore, MD 21230 410-537-3510 AI ID: 13670 Inspector: Brenden Hogan Site Name: Quarantine Road Municipal Landfill County: Baltimore City Inspection Date: September 16, 2015 Start Date/Time: September 16, 2015, 09:00 AM End Date /Time: September 16, 2015, 02:00 PM Media Type(s): NPDES Industrial Stormwater Contact(s): Raymond Riggin - Supervisor Tammy Roberson - MDE NPDES Industrial Stormwater Permit / Approval Numbers: 12SW0257 Site Status: Active Site Condition: Noncompliance Recommended Action: Additional Investigation Required Inspection Reason: Routine Scheduled, Joint Inspection MDE, Initial Quarterly, Initial Yearly Evidence Collected: Photos/Videos Taken, Visual Observation Inspection Findings: Today on September 16, 2015 a routine inspection was conducted for compliance with the NPDES General Permit for Stormwater Discharges Associated with Industrial Activity, Permit No. 12-SW at the Quarantine Road Municipal Landfill. The weather today was sunny and warm. During today s inspection I met with the landfill supervisor, Raymond Riggin. During today s inspection I was also accompanied by MDE Inspector Tammy Roberson, and several members of Baltimore City DPW as a part of a training exercise. Mr. Riggin was present for a records review of the site s General Discharge Permit and Stormwater Pollution Prevention Plan (SWPPP) and accompanied me for an inspection walkthrough of the facility.
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill Site Walkthrough The facility is approximately 201 acres in size and serves as a waste acceptance landfill receiving from citizens, small haulers, commercial haulers, and other city agencies. The facility is split into two parcels on opposite sides of Quarantine Road. The parcel on the West side of Quarantine Road is approximately 150 acres in size and contains the active disposal cell and citizen drop-off center. The parcel on the East side of Quarantine Road is approximately 51 acres in size and was previously owned by Millenium Organic Chemicals, Inc. used primarily for disposal of gypsum waste. Activities occurring on-site with potential pollutant sources include the active waste disposal cell, homeowner drop-off/recycling, cleaning of leachate lines, fueling of earth moving vehicles; and leachate collection, storage, separation, and disposal. The SWPPP contains a breakdown of percentages of each type of waste accepted at the facility. Baltimore RESCO Ash is the highest at 58%. Mr. Riggin stated that the ash is very corrosive to the machinery used on-site. Other potential pollutant sources listed in the SWPPP include the 1,000 gal aboveground storage tank (AST) of used oil near the citizen drop-off area, 55 gallon antifreeze drums, 55 gallon hydraulic fluid drums, 275 gallon totes of hydrochloric acid stored in a building on the West side of the old Millenium Landfill parcel, and 5,000 gallon leachate tanks located on the East side of the old Millenium landfill parcel. Drums within the storage building are placed on secondary containment trays. The used oil tank is double walled and within secondary containment beneath a cover structure. The secondary containment structure has an elevated open discharge pipe inside. Some staining was observed on the pavement near the used oil tank. Mr. Riggin stated that this was from the heavy equipment stored in the area. There is a storage shed for supplies nearby. There were no spill absorbents readily available in the storage shed during today s inspection to address potential spills/leaks. There are two leachate lagoons located at the Southwest corner of the facility. The leachate lagoons are concrete lined structures. There is a concrete pad above the lagoons where the pumping equipment is stored. The leachate is pumped from the site to the Patapsco Wastewater Treatment Plant. Leachate from the facility on the East side of Quarantine Road is conveyed to this area as well. Leachate was observed being discharged into the lagoons during today s inspection. Mr. Riggin stated that the site has not had any significant spills from pump malfunctions. There are a total of seven outfalls indicated on the site map in the SWPPP. Five of the outfalls are around the landfill parcel on the West side of Quarantine Road. These include Outfalls 1, 2A, 2B, 3, and 4. Outfalls 5 and 6 are on the old Millenium landfill parcel on the East side of Quarantine Road. The receiving water of the facility is identified as the Patapsco River-Baltimore Harbor. Basin #3 which is located at the Southeast corner of the Quarantine Landfill discharges to Outfall 1 next to the ramp to Interstate 695. Stormwater was not observed within Basin #3. Storm drain inlets near the citizen drop-off area are conveyed to Basin #3. Basin #1 and Basin #2 are located next to the leachate lagoons at the Southwest corner of the Quarantine Landfill. Stone gabion channels convey stormwater from the top of the landfill to these basins. Mr. Riggin explained that the basins are then piped beneath the perimeter road and discharge to Outfalls 2A and 2B. Basin #4 is located on the West side of the Quarantine Landfill. Similar stone gabion channel structures convey stormwater to the basin. Water within the basin was observed to be turbid. A Page 2
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill damaged baffle board was present within the basin. The dewatering device to the riser structure was observed to have vegetation growing from it. This may indicate that the dewatering device is clogged with sediment and is not functioning properly. It was recommended to Mr. Riggin during today s inspection that the dewatering device be properly maintained free of sediment build-up. Mr. Riggin had noted this corrective action on the most recent inspection report. Basin #4 discharges to Outfall 3 on the West side of the perimeter road via underground piping. Sedimentladen water was not observed in the discharge at Outfall 3. Basin A is located on the Northwest side of the facility. The haul road and the cell boundary of active cell #6 are located upslope of Basin A (see photos). Inlet protection to Basin A was observed to be damaged leaving exposed sediment to stormwater runoff (see photos). Sediment deposition was observed at the bottom of the inlet to Basin A (see photos). The horizontal dewatering device beneath the riser structure in Basin A has been removed; however the pipe stub is still open placing the sediments in a position to discharge and pollute Waters of the State (see photos). Basin A discharges to Outfall 4 on the West side of the perimeter road via underground piping. The discharge could not be observed due to the dense vegetation along the perimeter of the facility. It was explained to Mr. Riggin that these issues should be addressed immediately to prevent potential sediment runoff pollution. Outfall 5 is located on the East side of the old Millenium landfill parcel from Basin M-1. Stone gabion channels convey stormwater to this basin. This basin was observed to be dry. No discharge was observed at this outfall. Outfall 6 is located on the West side of the old Millenium landfill parcel from Outlet Trap #1. This outfall discharges to Quarantine Road. Records Review The facility received coverage under the new State/National Pollution Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity, Permit No. 12-SW on 8/11/14. Mr. Riggin was able to provide a copy of the site s Stormwater Pollution Prevention Plan (SWPPP) upon request during today s inspection. The SWPPP was developed in June 2014 by ARM Group, Inc. and was signed and certified by Vivaldi Nguyen (Solid Waste Engineer) on 6/27/14. Mr. Nguyen is listed as the primary SWPPP contact and is at the head of the SWPPP team. Mr. Riggin is also identified as a member of the SWPPP team. Mr. Riggin was able to present records today for daily inspections of landfill operations. The most recent inspection report was dated 9/15/15. The inspections include reviews of the leachate conveyance system, erosion and sediment controls, the landfill gas collection system, the active fill area, litter controls, and the perimeter road. Although the facility has daily inspection records, it should also be implementing and documenting annual comprehensive site inspections per Permit requirements. No annual comprehensive inspection records were available for review during today s inspection and the SWPPP has not been updated since June 2014, over one year ago. Mr. Riggin explained that visual monitoring of outfalls is incorporated into the daily inspections. Visual monitoring points are not indicated on the site map of the SWPPP. The facility should be performing visual monitoring in accordance to Permit conditions by collecting a sample at each outfall during a precipitation event. The visual monitoring form is present in the copy of the SWPPP on-site, but has not been used. It was recommended to Mr. Riggin that separate forms be used to demonstrate quarterly visual monitoring at the outfalls has been completed. Page 3
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill During today s inspection it was determined that the facility has not been following the compliance schedule in accordance to Permit conditions for benchmark monitoring. The facility SIC code is listed as 4953, LF. The facility is subject to benchmark monitoring for the parameters of Total Suspended Solids (TSS) and Total Iron. After telephone conversation with the Department s Program today, it was determined that the facility has not registered for a NetDMR account for benchmark monitoring reporting. Mr. Riggin was not aware of the additional benchmark monitoring requirements when questioned today. The SWPPP on-site acknowledges the applicable benchmark monitoring requirements. Mr. Riggin explained that the facility implements routine stormwater pollution prevention training to its employees. There was no documentation available on-site to support this. Mr. Riggin agreed to begin documenting annual employee SWPPP training per Permit requirements. With respect to the above MDE authorization, the following violations of Environment Article Title 4, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Sediment deposition was observed in Basin A. Inlet protection above Basin A has been damaged and sediments are exposed to stormwater runoff. The dewatering pipe stub below the riser structure is currently not sealed off. Sediments are in a position to pollute Waters of the State. The facility should temporarily cap off the open pipe stub below the riser structure in Basin A to prevent sediments from leaving the site. The damaged inlet protection should be addressed and excess sediment deposits removed from the basin within 14 days of receipt of the inspection report. Sediments should not be placed in a position to pollute Waters of the State. With respect to the above MDE authorization, the following violations of Environment Article Title 9, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) There were no annual employee training records in regards to the SWPPP available for review on-site. The facility should implement annual SWPPP training and maintain copies of training records on-site with the SWPPP. 2) Visual monitoring records are inadequate. Current inspection sheets do not follow proper sampling procedures for quarterly visual monitoring requirements per Permit conditions. Visual monitoring points are not indicated on the site map of the SWPPP. The facility should implement at a minimum quarterly visual monitoring of outfalls on-site and maintain records with the SWPPP. The site map should be updated to reflect the location of the monitoring points. 3) The facility is not following the compliance schedule in accordance to Permit conditions. The facility failed to register for NetDMR for benchmark monitoring reporting within one month or receiving coverage under the Permit No. 12-SW. Benchmark monitoring has not been conducted on-site and reported in accordance to Permit conditions for Total Suspended Solids (TSS) and Total Iron. The first quarter of benchmark monitoring reports has been missed. The facility should follow the compliance schedule in accordance to Permit conditions. The facility should setup the NetDMR account and begin collecting benchmark samples and reporting them to the Department as soon as possible. Page 4
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill 4) There were no records of annual comprehensive site inspections available for review. There are no records to indicate the SWPPP has been reviewed since June 2014. The facility should implement and document annual comprehensive site inspections per Permit conditions. 5) The dewatering device in Basin #4 is not being properly maintained. There is evidence of excess sediment build-up in the stone of the dewatering device due to established vegetation. The facility should work to implement maintenance procedures of the dewatering device in Basin #4. 6) There is evidence of staining on the pavement from equipment storage near the used oil tank. There are no spill absorbents currently readily available in the area. The facility should maintain spill kits/absorbents on-site in areas where spills/leaks/drips could occur. STATE LAW PROVIDES FOR PENALTIES FOR VIOLATIONS OF MARYLAND ENVIRONMENT ARTICLE TITLE 9 FOR EACH DAY THE VIOLATION CONTINUES. THE MARYLAND DEPARTMENT OF THE ENVIRONMENT MAY SEEK PENALTIES FOR THE AFOREMENTIONED VIOLATIONS OF TITLE 9 ON THIS SITE FOR EACH DAY THE VIOLATION CONTINUES. For additional information on the Permit No. 12-SW, contact the Department s Industrial and General Permits Division at 410-537-3323 or see the following link with guidance documents: http://www.mde.maryland.gov/programs/permits/watermanagementpermits/waterdischargepermita pplications/pages/permits/watermanagementpermits/water_applications/stormwater.aspx For questions and information regarding NetDMR and benchmark reporting, contact Bill Lee of the Department s Program-Enforcement Division at 410-537-3514 or at wlee@maryland.gov. A follow-up inspection of this facility will be conducted in approximately 14 days. Any questions regarding this report can be referred to Brenden Hogan at 410-537-3978 or at brenden.hogan@maryland.gov. A copy of this report has been submitted to Mr. Riggin of the Quarantine Road Municipal Landfill. Page 5
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 1. Does the facility have a discharge permit? [Environment Article 9-323a(1-3)] 2. Is the discharge permit current? Has facility applied for renewal? [Environment Article 9-328a(1)] 3. Is the facility as described in the current permit? Are treatment processes as described in the current permit? [COMAR 26.08.04.01.01B(4)] 4. Has notification been submitted about any new, different or increased discharges? [40 CFR Part 122 Subpart C Section 122.42.b(1-3)] 5. Is the number and location of discharge points as described in the discharge permit? [Environment Article 9-3314] 6. Has permittee submitted correct name and address of receiving waters? [40 CFR 122.21.j(3)] 7. Is the permittee meeting the compliance schedule per permit requirements? [COMAR 26.08.04.02-1.02-1A(3)] 8. Has the operator or superintendent been certified by the Board in the appropriate classification for the facility? [COMAR 26.06.01.05A(1)] 9. Are adequate records being maintained for the sampling date, time, and exact location; analysis dates and times; individual performing analysis; and analytical results? [COMAR 26.08.04.03.03B(3)(a, b, c, e)] 10. Are adequate records being maintained for the analytical methods/techniques used? [COMAR 26.08.04.03.03B(3)(d)] 11. Does the permittee retained a minimum of 3 years worth of monitoring records including raw data and original strip chart recordings; calibration and maintenance records; and reports? [COMAR 26.08.04.03.03B(1)] 12. Is the lab and monitoring equipment being properly calibrated and maintained? Are they keeping records to reflect this? [Environment Article 9-3313] 13. Is laboratory controls and appropriate quality assurance procedures properly operated and maintained? [40 CFR Part 122 Subpart C Section 122.41.e] 14. Has the permittee submitted the monitoring results on the proper Discharge Monitoring Report form? [COMAR 26.08.04.03.03C(1)] The facility received coverage under the Permit No. 12- SW on 8/11/14. The facility received coverage under the Permit No. 12- SW on 8/11/14. The compliance schedule is not being followed in accordance to Permit conditions. See findings. See findings. See findings. Page 6
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 15. Has the permittee submitted these results within the allotted time? [COMAR 26.08.04.03.03C(2)] 16. Are discharge monitoring reports complete and reflect permit conditions? [COMAR 26.08.04.03B(3)] 17. Is the facility being properly operated and maintained including:(a) stand-by power or equivalent provisions available, (b) adequate alarm system for power or equipment failure available, (c) all treatments units are in service,. [40 CFR Part 122 Subpart C Section 122.41.e] 18. Is sewage sludge managed correctly per permit requirements? [COMAR 26.04.06.03.03] 19. Any by-pass since last inspection? Has permittee submitted notice of any by-pass? [40 CFR Part 122 Subpart C Section 122.41.m(4)(i)(C)] 20. Any non-complying discharges experienced since last inspection? Has regulatory agency been notified? [40 CFR Part 122 Subpart C Section 122.41.l(6)] 21. Have overflows occurred since the last inspection? [COMAR 26.08.10.02A] 22. Has records of overflows been maintained at the facility for at least five years? [COMAR 26.08.10.06A-B] 23. Are flow measuring devices properly installed and operated, calibration frequency of flow meter adequate, flow measurement equipment adequate to handle expected ranges of flow? [40 CFR Part 122 Subpart C Section 122.41.e] 24. Are discharge monitoring points adequate for representative sampling? Do parameters and sampling frequency meet the minimum requirements? Does the permittee use the method of sample collection required by the permit? [Environment Article 9-331(4)] 25. Are analytical testing procedures approved by EPA? If alternate analytical procedures are used, proper approval has been obtained? [COMAR 26.08.01.02B(1)] 26. Has the permittee notified the Department of the name and address of the commercial laboratory? [COMAR 26.08.04.03.03A(3)] Evaluated Evaluated The facility has not set up the NetDMR account for benchmark monitoring reporting. Benchmark monitoring has not been completed per Permit requirements. Visual monitoring reports of discharges are not adequate. See findings. Discharge monitoring points are not indicated within the SWPPP. Records do not indicate samples were taken for visual monitoring of outfalls. Benchmark monitoring has not been completed per Permit requirements. Page 7
Inspection Date: September 16, 2015 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 27. Were discharges observed at the authorized outfalls? Does the facility have any unauthorized discharges to waters of the State? [Environment Article 9-322] 28. Does the discharges or receiving waters have any visible pollutants (oil sheen, grease, turbidity, foam, floating solids, color), odor, noncompliant DO concentrations, and/or noncompliant temperature ranges? [Environment Article 9-314b(1)] 29. Were discharge samples collected? [Environment Article 9-261c(1)] 30. Is the facility required to have a storm water pollution prevention plan? Has storm water pollution prevention plan been developed and implemented as required? Does storm water pollution prevention plan require modifications to prevent runoff of pollutants? [40 CFR Part 122 Subpart B Section 122.26.c(1)(I)(A-B)] 31. Are the permit conditions being met? [Environment Article 9-326a(1)] Info Info Evaluated Sediment deposition was observed at Basin A in a position to pollute Waters of the State from damaged inlet protection. Dewatering device at Basin 4 requires maintenance due to excess sediment build-up on the stone with vegetative growth. Unauthorized discharges were not observed at the outfall locations. Sediment deposition was observed at Basin A in a position to pollute Waters of the State from damaged inlet protection. Dewatering device at Basin 4 requires maintenance due to excess sediment build-up on the stone with vegetative growth. See findings. See findings. Inspector: Brenden Hogan/9/16/15 brenden.hogan@maryland.gov 410-537-3978 Received by: Signature/Date Print Name Report Provided to: Raymond Riggin [ ] Fax [ ] Email Raymond.riggin@baltimorecity.gov [ ] Regular Mail [ ] Certified Mail Page 8
BCH, 9/16/15, Baltimore City, Quarantine Road Municipal Landfill, 12-SW-0257 Photo #1- Sediment deposition to Basin A. Damaged inlet protection with exposed sediments. Photo #2- The inlet protection to Basin A (facing upslope towards active Cell #6 and the haul road). BCH, 9/16/15, Baltimore City, Quarantine Road Municipal Landfill, 12-SW-0257
BCH, 9/16/15, Baltimore City, Quarantine Road Municipal Landfill, 12-SW-0257 Photo #3- The pipe stub from the dewatering device is open inside of Basin A. Sediment is in a position to discharge and pollute Waters of the State. Photo #4- Damaged inlet protection and sediment deposition to Basin A. BCH, 9/16/15, Baltimore City, Quarantine Road Municipal Landfill, 12-SW-0257
Maryland Department of Environment Water Management Administration Program 1800 Washington Blvd, Baltimore, MD 21230 410-537-3510 AI ID: 13670 Inspector: Brenden Hogan Site Name: Quarantine Road Municipal Landfill County: Baltimore City Inspection Date: September 30, 2015 Start Date/Time: September 30, 2015, 01:15 PM End Date /Time: September 30, 2015, 03:00 PM Media Type(s): NPDES Industrial Stormwater Contact(s): Vivaldi Nguyen - Engineer/Supervisor Joana Pei - Baltimore City DPW Raymond Riggin - Supervisor NPDES Industrial Stormwater Permit / Approval Numbers: 12SW0257 Site Status: Active Site Condition: Noncompliance Recommended Action: Additional Investigation Required Inspection Reason: Follow-up (Non-) Evidence Collected: Photos/Videos Taken, Visual Observation Inspection Findings: Today on September 30, 2015 a follow-up inspection was conducted for noncompliance with the Maryland General Discharge Permit for Industrial Stormwater at the Quarantine Road Municipal Landfill. The weather today was warm and cloudy with light precipitation at times. During today s inspection I met with Raymond Riggin (Landfill Supervisor), Vivaldi Nguyen (Engineer/Supervisor), and Joana Pei (Baltimore City DPW). Mr. Nguyen and Mr. Riggin accompanied me for an inspection walkthrough of the facility. All were present for a records review of the site s General Discharge Permit and Stormwater Pollution Prevention Plan (SWPPP). Mr. Nguyen is the current primary contact for the SWPPP. Since the previous inspection the facility has been working to get back into compliance. During the previous inspection dated 9/16/15, there was damaged inlet protection with exposed sediment
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill observed above Basin A. The pipe stub for the dewatering device on the riser structure was observed open, placing sediments in a position to pollute Waters of the State. Since the previous inspection, the facility has temporarily capped the opening below the riser structure with a rubber plug to prevent sediment runoff. This was done on Monday (9/28/15). Mr. Riggin provided photos of the cap. The water level in Basin A was observed to be above the vortex structure during today s inspection (see photos). The inlet protection above Basin A is still damaged and has exposed sediment (see photos). Mr. Nguyen explained that the facility got a cost proposal to make the necessary repairs to the channel last Friday. The water below the damaged inlet was observed to have floating sediment. Some debris was observed floating in the water of Basin A (see photos). There was sediment runoff observed from the cell across the haul road towards the channel to Basin A (see photos). The facility placed #2 stone at the point of runoff in an attempt to control the sediment. The silt fence along the haul road was observed to be damaged (see photos). The facility should maintain sediment and erosion controls on-site. Maintenance of the dewatering device in Basin 4 has not yet been addressed. There is still evidence of excess sediment build-up in the stone of the dewatering device due to established vegetation. Mr. Riggin explained that the facility plans to address the issue soon. Mr. Riggin and Mr. Nguyen explained that the facility plans to gain access to each of the outfalls on-site to successfully perform visual and benchmark monitoring in accordance to Permit conditions. The facility has not yet registered a NetDMR account for benchmark monitoring reporting. Ms. Pei has signed up for a NetDMR class on October 7 th, and then will gain access to NetDMR for benchmark monitoring/reporting after the class has been taken. Mr. Nguyen explained that the facility plans to use KCI Labs for benchmark monitoring results. Once the contract is sorted out benchmark monitoring will be conducted. Mr. Riggin explained that the facility will document an annual comprehensive site inspection once access has been gained to each outfall. Annual employee training has not yet been conducted in accordance to Permit conditions. The facility has gotten new spill absorbents/pads for the storage container near the used oil tank. Mr. Riggin showed me these spill absorbent materials during today s inspection. Mr. Nguyen explained that positions are changing and there will most likely be a new primary contact for the SWPPP for this facility. With respect to the above MDE authorization, the following violations of Environment Article Title 4, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Sediment runoff was observed flowing across the haul road towards the inlet to Basin A. Silt fence along the haul road was damaged and not functioning properly. Inlet protection above Basin A is still damaged and sediments are exposed to stormwater runoff. The facility should maintain sediment and erosion controls on-site and work to prevent sediment runoff to Basin A. Page 2
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill With respect to the above MDE authorization, the following violations of Environment Article Title 9, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) There were no annual employee training records in regards to the SWPPP available for review on-site. The facility should implement annual SWPPP training and maintain copies of training records on-site with the SWPPP. 2) Visual monitoring records are inadequate. Current inspection sheets do not follow proper sampling procedures for quarterly visual monitoring requirements per Permit conditions. Visual monitoring points are not indicated on the site map of the SWPPP. The facility should implement at a minimum quarterly visual monitoring of outfalls on-site and maintain records with the SWPPP. The site map should be updated to reflect the location of the monitoring points. 3) The facility is not following the compliance schedule in accordance to Permit conditions. The facility failed to register for NetDMR for benchmark monitoring reporting within one month or receiving coverage under the Permit No. 12-SW. Benchmark monitoring has not been conducted on-site and reported in accordance to Permit conditions for Total Suspended Solids (TSS) and Total Iron. The first quarter of benchmark monitoring reports has been missed. The facility should follow the compliance schedule in accordance to Permit conditions. The facility should setup the NetDMR account and begin collecting benchmark samples and reporting them to the Department as soon as possible. 4) There were no records of annual comprehensive site inspections available for review. There are no records to indicate the SWPPP has been reviewed since June 2014. The facility should implement and document annual comprehensive site inspections per Permit conditions. 5) The dewatering device in Basin #4 is not being properly maintained. There is evidence of excess sediment build-up in the stone of the dewatering device due to established vegetation. The facility should work to implement maintenance procedures of the dewatering device in Basin #4. STATE LAW PROVIDES FOR PENALTIES FOR VIOLATIONS OF MARYLAND ENVIRONMENT ARTICLE TITLE 9 FOR EACH DAY THE VIOLATION CONTINUES. THE MARYLAND DEPARTMENT OF THE ENVIRONMENT MAY SEEK PENALTIES FOR THE AFOREMENTIONED VIOLATIONS OF TITLE 9 ON THIS SITE FOR EACH DAY THE VIOLATION CONTINUES. For additional information on the Permit No. 12-SW, contact the Department s Industrial and General Permits Division at 410-537-3323 or see the following link with guidance documents: http://www.mde.maryland.gov/programs/permits/watermanagementpermits/waterdischargepermita pplications/pages/permits/watermanagementpermits/water_applications/stormwater.aspx For questions and information regarding NetDMR and benchmark reporting, contact Bill Lee of the Department s Program-Enforcement Division at 410-537-3514 or at wlee@maryland.gov. Page 3
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill A follow-up inspection of this facility will be conducted in approximately 30 days. Any questions regarding this report can be referred to Brenden Hogan at 410-537-3978 or at brenden.hogan@maryland.gov. A copy of this report has been submitted to Mr. Riggin of the Quarantine Road Municipal Landfill. NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 1. Does the facility have a discharge permit? [Environment Article 9-323a(1-3)] 2. Is the discharge permit current? Has facility applied for renewal? [Environment Article 9-328a(1)] 3. Is the facility as described in the current permit? Are treatment processes as described in the current permit? [COMAR 26.08.04.01.01B(4)] 4. Has notification been submitted about any new, different or increased discharges? [40 CFR Part 122 Subpart C Section 122.42.b(1-3)] 5. Is the number and location of discharge points as described in the discharge permit? [Environment Article 9-3314] 6. Has permittee submitted correct name and address of receiving waters? [40 CFR 122.21.j(3)] 7. Is the permittee meeting the compliance schedule per permit requirements? [COMAR 26.08.04.02-1.02-1A(3)] 8. Has the operator or superintendent been certified by the Board in the appropriate classification for the facility? [COMAR 26.06.01.05A(1)] 9. Are adequate records being maintained for the sampling date, time, and exact location; analysis dates and times; individual performing analysis; and analytical results? [COMAR 26.08.04.03.03B(3)(a, b, c, e)] 10. Are adequate records being maintained for the analytical methods/techniques used? [COMAR 26.08.04.03.03B(3)(d)] 11. Does the permittee retained a minimum of 3 years worth of monitoring records including raw data and original strip chart recordings; calibration and maintenance records; and reports? [COMAR 26.08.04.03.03B(1)] The compliance schedule is not being followed in accordance to Permit conditions. See findings. See findings. See findings. Page 4
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 12. Is the lab and monitoring equipment being properly calibrated and maintained? Are they keeping records to reflect this? [Environment Article 9-3313] 13. Is laboratory controls and appropriate quality assurance procedures properly operated and maintained? [40 CFR Part 122 Subpart C Section 122.41.e] 14. Has the permittee submitted the monitoring results on the proper Discharge Monitoring Report form? [COMAR 26.08.04.03.03C(1)] 15. Has the permittee submitted these results within the allotted time? [COMAR 26.08.04.03.03C(2)] 16. Are discharge monitoring reports complete and reflect permit conditions? [COMAR 26.08.04.03B(3)] 17. Is the facility being properly operated and maintained including:(a) stand-by power or equivalent provisions available, (b) adequate alarm system for power or equipment failure available, (c) all treatments units are in service,. [40 CFR Part 122 Subpart C Section 122.41.e] 18. Is sewage sludge managed correctly per permit requirements? [COMAR 26.04.06.03.03] 19. Any by-pass since last inspection? Has permittee submitted notice of any by-pass? [40 CFR Part 122 Subpart C Section 122.41.m(4)(i)(C)] 20. Any non-complying discharges experienced since last inspection? Has regulatory agency been notified? [40 CFR Part 122 Subpart C Section 122.41.l(6)] 21. Have overflows occurred since the last inspection? [COMAR 26.08.10.02A] 22. Has records of overflows been maintained at the facility for at least five years? [COMAR 26.08.10.06A-B] 23. Are flow measuring devices properly installed and operated, calibration frequency of flow meter adequate, flow measurement equipment adequate to handle expected ranges of flow? [40 CFR Part 122 Subpart C Section 122.41.e] The facility has not set up the NetDMR account for benchmark monitoring reporting. Benchmark monitoring has not been completed per Permit requirements. Visual monitoring reports of discharges are not adequate. Page 5
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 24. Are discharge monitoring points adequate for representative sampling? Do parameters and sampling frequency meet the minimum requirements? Does the permittee use the method of sample collection required by the permit? [Environment Article 9-331(4)] 25. Are analytical testing procedures approved by EPA? If alternate analytical procedures are used, proper approval has been obtained? [COMAR 26.08.01.02B(1)] 26. Has the permittee notified the Department of the name and address of the commercial laboratory? [COMAR 26.08.04.03.03A(3)] 27. Were discharges observed at the authorized outfalls? Does the facility have any unauthorized discharges to waters of the State? [Environment Article 9-322] 28. Does the discharges or receiving waters have any visible pollutants (oil sheen, grease, turbidity, foam, floating solids, color), odor, noncompliant DO concentrations, and/or noncompliant temperature ranges? [Environment Article 9-314b(1)] 29. Were discharge samples collected? [Environment Article 9-261c(1)] 30. Is the facility required to have a storm water pollution prevention plan? Has storm water pollution prevention plan been developed and implemented as required? Does storm water pollution prevention plan require modifications to prevent runoff of pollutants? [40 CFR Part 122 Subpart B Section 122.26.c(1)(I)(A-B)] 31. Are the permit conditions being met? [Environment Article 9-326a(1)] Evaluated Info Info Info Evaluated Discharge monitoring points are not indicated within the SWPPP. Records do not indicate samples were taken for visual monitoring of outfalls. Benchmark monitoring has not been completed per Permit requirements. The facility plans on using KCI Labs for benchmark monitoring. Damaged inlet protection above Basin A remains. Evidence of sediment runoff across the haul road above Basin A with damaged sediment/erosion controls. Basin A has been plugged to prevent sediment runoff. Floating debris and some sediment-laden water was observed in Basin A. Dewatering device at Basin 4 requires maintenance due to excess sediment build-up on the stone with vegetative growth. Unauthorized discharges were not observed at the outfall locations. Damaged inlet protection above Basin A remains. Evidence of sediment runoff across the haul road above Basin A with damaged sediment/erosion controls. Basin A has been plugged to prevent sediment runoff. Floating debris and some sediment-laden water was observed in Basin A. Dewatering device at Basin 4 requires maintenance due to excess sediment build-up on the stone with vegetative growth. Unauthorized discharges were not observed at the outfall locations. See findings. See findings. Page 6
Inspection Date: September 30, 2015 Site Name: Quarantine Road Municipal Landfill Inspector: Brenden Hogan/9/30/15 brenden.hogan@maryland.gov 410-537-3978 Received by: Signature/Date Print Name Report Provided to: Raymond Riggin [ ] Fax [ ] Email Raymond.riggin@baltimorecity.gov [ ] Regular Mail [ ] Certified Mail Page 7
BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #1- Basin A after the dewatering opening of the riser structure has been capped. Photo #2- Debris observed in the water of Basin A. BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #3- Damaged inlet protection remains leaving exposed sediment to stormwater runoff. e the sediment laden water in Basin A and the capped riser structure. Photo #4- Sediment runoff across the haul road from the active cell. BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #5- Silt fence overtaken by sediment runoff along the haul road. Photo #6- Damaged silt fence and exposed sediment above Basin A. BCH, 9/30/15, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
Maryland Department of Environment Water Management Administration Program 1800 Washington Blvd, Baltimore, MD 21230 410-537-3510 AI ID: 13670 Inspector: Brenden Hogan Site Name: Quarantine Road Municipal Landfill County: Baltimore City Inspection Date: March 16, 2016 Start Date/Time: March 16, 2016, 09:00 AM End Date /Time: March 16, 2016, 01:00 PM Media Type(s): NPDES Industrial Stormwater Contact(s): Douglas Carter - Acting Chief-Landfill Superintendent Dean Bullis- MDE (LMA) NPDES Industrial Stormwater Permit / Approval Numbers: 12SW0257 PAF Number: 16-2308 Site Status: Active Site Condition: Noncompliance Recommended Action: Additional Investigation Required, Refer to Others (See Findings) Inspection Reason: Initial Quarterly, Initial Yearly, PAF, Joint Inspection MDE Evidence Collected: Photos/Videos Taken, Visual Observation Inspection Findings: Today on March 16, 2016 an unannounced joint inspection with Dean Bullis of the Department s Land Management Administration was conducted at the Quarantine Road Municipal Landfill. Mr. Bullis referred pollution issues occurring on the site from an inspection dated 3/3/16 to the Water Management Administration. The pollution issues were related to major erosion problems occurring on-site and exposed incinerator ash waste to stormwater runoff. This inspector conducted an inspection today for the site s State/National Pollution Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Industrial Activity, Permit No. 12-SW. During today s inspection Mr. Bullis and I met with Douglas Carter, Acting Chief/Landfill Superintendent. Mr. Carter was present for a records review of the site s Permit No. 12-SW and
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill Stormwater Pollution Prevention Plan (SWPPP) and accompanied us for an inspection walkthrough of the facility. No sediment/erosion control plans were reviewed during today s inspection. The weather conditions today were sunny with mild temperatures. The facility is approximately 201 acres in size and serves as a waste acceptance landfill receiving from citizens, small haulers, commercial haulers, and other city agencies. The landfill is operated by Baltimore City. The facility is split into two parcels on opposite sides of Quarantine Road. The parcel on the West side of Quarantine Road is approximately 150 acres in size and contains the active disposal cell and citizen drop-off center. The parcel on the East side of Quarantine Road is approximately 51 acres in size and was previously owned by Millenium Organic Chemicals, Inc. used primarily for disposal of gypsum waste. Activities occurring on-site with potential pollutant sources include the active waste disposal cell, homeowner drop-off/recycling, cleaning of leachate lines, fueling of earth moving vehicles; and leachate collection, storage, separation, and disposal. The SWPPP contains a breakdown of percentages of each type of waste accepted at the facility. Baltimore RESCO Ash is the highest at 58%. The leachate lagoons at the Southwest corner of the facility were observed. Outfall 2A from Basin 1 was observed. A discharge was noted (see photos). Outfall 2B on the West side of the leachate lagoons from Basin 2 was also observed to have a discharge even though Basin 2 appeared relatively dry during today s inspection (see photos). Basin 4 was observed on the West side of the landfill. Sediment accumulation was observed at the bottom of the stone channel to Basin 4. The basin had standing red/turbid water present within (see photos). Similar discharge was noted at Outfall 3 from Basin 4 (see photos). It was observed that the dewatering device in Basin 4 still had vegetation present which indicates sedimentation build-up and a lack of maintenance. This issue was present during the previous inspection (see report dated 9/30/15) and has not been addressed. Basin A along the Northwest perimeter of the landfill was observed. There is a damaged inlet structure to the Basin that conveys runoff from the active cell 6 and the haul road above (see photos). This damaged inlet was observed during previous inspections in September 2015 and still has not been addressed. Mr. Carter explained that there is a lack of agreement for responsibility between the contractor that performed the original work on the inlet channel and the City of Baltimore, so no repairs have been completed. There is evidence to show that water from Basin A has been overflowing and causing erosion along the South perimeter (see photos). Plans for this basin were not reviewed during today s inspection. It is important to note that the pipe stub below the riser structure is still sealed. This was to be a temporary measure to prevent potential sediment pollution from the Basin while the inlet protection to Basin A was repaired. Inlet protection to Basin A has not been repaired, and the pipe stub below the riser structure has remained sealed causing the water level to stay high in the Basin. Trash and floatable debris was observed along the banks of Basin A during today s inspection. The face of the active cell 6 was observed upslope of Basin A along the haul road. This is the area where Mr. Bullis observed ash runoff from the active cell towards the Basin, and directed the facility to provide adequate cover of the ash and waste in the active cell. The SWPPP notes that preventative maintenance shall be performed to maintain the integrity of intermediate and final cover at the landfill. During today s inspection similar ash waste exposure and runoff was observed from the top of the active cell. Ash was observed running off the face of the West slope towards the haul road and drainage culvert to Basin A (see photos). Mr. Carter explained that the Page 2
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill facility has been working to provide adequate clean soil top cover to the ash and waste in the active cell. Mr. Carter stated that the ash running along the slopes cannot yet be removed because the ground is too wet for the equipment to work in the area. Sediment/erosion controls along the haul road were not being properly maintained. Silt fence was down and erosion was present along the culvert to the damaged inlet to Basin A (see photos). Mr. Carter accompanied us across Quarantine Road to the Millenium Landfill parcel. Outfall 5 was observed to have a discharge during today s inspection. This discharge was not observed to be red colored/turbid like the other outfalls. Just South of Outfall 5 there is a pump station shed. A strong odor and an active leachate discharge were observed in this area (see photos). The discharge was observed to be slowly upwelling from the pipes in the ground. Mr. Carter stated that this was the first he was aware of this leachate discharge occurring. Mr. Carter attributed the cause of the discharge at the time of inspection to failing leachate pump and conveyance systems on the property. The leachate tanks are filling without the necessary pump, causing the release. Mr. Carter stated that the facility has been having problems for approximately two weeks with the pumps onsite functioning properly and stated that personnel have been working to fix the problem. Mr. Bullis and I followed the discharge until it stopped right before a monitoring well (see photos). The discharge was seeping into the ground at this point. The tributary to the North of Outfall 5 was observed to see if there was any potential impact from the leachate discharge to surface waters (see photos). No strong leachate odor or unusual discharges were observed in the tributary. Mr. Carter stated during today s inspection that he would bring a vac truck to the leachate discharge area as soon as possible to clean up the release and pump and haul the leachate to the lagoons on the other side of the facility. Mr. Carter stated that the facility is actively trying to fix the issue with the malfunctioning pumping system. The facility was last inspected on September 30, 2015 by this inspector. Mr. Carter stated that Mr. Ray Riggin, the old Landfill Superintendent no longer works at this facility. Mr. Carter is now the Acting Chief and Landfill Superintendent. Mr. Carter was able to provide a copy of the site s Stormwater Pollution Prevention Plan (SWPPP). The SWPPP was dated June 2014. The SWPPP was reviewed prior to the inspection walkthrough. The SWPPP team still notes Mr. Riggin as a head member with responsibilities to implement the SWPPP. It was explained to Mr. Carter that the SWPPP team should be updated to reflect the change in site personnel and responsibilities. Mr. Carter explained that since the previous inspection the facility has hired KCI Technologies to come in and perform quarterly visual monitoring and benchmark monitoring. The discharge monitoring reports were reviewed through NetDMR pre-inspection. The facility reported benchmark monitoring results for the fourth quarter of 2015. Vivaldi Nguyen (Site Engineer) is listed as the signatory authority for the NetDMR account. The facility has a total of seven listed outfalls on the SWPPP site map. The facility reported benchmark monitoring results for the first time for the fourth quarter of 2015. The only outfall that was reported for the parameters of total iron and total suspended solids was Outfall 5. The sampling results exceeded both benchmark values. TSS was reported to have a value of 220 mg/l. Total Iron was reported to have a value of 21 mg/l. The remaining outfalls were listed to have no discharge. Outfall 5 is located on the East side of the Millenium landfill parcel, which is not the active part of the landfill operation. None of the outfalls on the active side of the landfill were sampled. The only quarterly visual monitoring report in the SWPPP sampled Outfall 5; none of the other outfalls were visually sampled. Benchmark monitoring and visual monitoring were both done on the same day, 10/28/15. The notes for KCI Technologies sampling reports were reviewed to determine the reason only one of the outfalls was reported. No flow was reported in all of the Outfalls except for Outfall 5. KCI noted Page 3
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill that they could not locate Outfall 2B or physically observe Basin 1. It was discussed with the facility today and during previous inspections that access should be provided to all outfalls on-site for sampling and monitoring purposes. During today s inspection we were able to access and locate all seven outfalls with the use of the SWPPP site map. Discharges were observed from every outfall except Outfall 6 on the Millenium parcel (see photos), and no precipitation was occurring during the inspection. Mr. Carter explained that the facility still performs daily site inspections. Mr. Carter stated that Baltimore City personnel come in to perform the inspections in regards to the Permit No. 12-SW. Copies of these inspection reports were not available for review during today s inspection. The facility performed annual employee SWPPP training on 11/16/15. With respect to the above MDE authorization the following violations of Environment Article, Title 4 by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Sediment deposition was observed in Basin A. Inlet protection above Basin A has been damaged and sediments are exposed to stormwater runoff. Damaged inlet protection has not been addressed per the previous issuance of inspection reports. Sediments are in a position to pollute Waters of the State. The damaged inlet protection to Basin A should be addressed. Excess sediment deposits to Basin A should be mucked out and removed. Sediments should not be placed in a position to pollute Waters of the State. 2) There is evidence showing that the water from Basin A is overflowing along the South perimeter of the basin and causing erosion. The facility should evaluate the basin specifications per the approved plan and implement changes necessary to prevent further overflows and erosion. 3) Sediment controls along the haul road above Basin A are not functioning properly. Silt fence was observed damaged and there is evidence of erosion. The facility should implement and repair sediment/erosion controls along the haul road above Basin A. With respect to the above MDE authorization the following violations of Environment Article, Title 9 by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Landfill leachate was observed discharging near a pump station on the East side of the Millenium Landfill parcel near Outfall 5 due to malfunctioning pumping systems on-site. The discharge was observed seeping into the grounds and was not directly discharging to surface waters. The facility should immediately address any leachate releases, spills, drips upon discovery. The facility should fix the pumping and leachate conveyance systems to prevent further releases to the environment. The discharged leachate should be cleaned up, pumped, and hauled to a proper treatment and disposal facility (TSDF) immediately. 2) The facility has not been applying adequate cover per the SWPPP for the incoming ash and waste in the active cell, and as a result contaminants have been placed in a position likely to runoff and pollute Waters of the State. The facility should address adequate cover of exposed waste Page 4
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill per the direction of the Department s Land Management Administration. Ash and other waste pollutants that have runoff the slopes from the active cell should be removed and placed in a position not likely to runoff and pollute Waters of the State. Any contaminated stormwater within the basins on-site should be pumped and hauled to a proper treatment and disposal facility (TSDF). 3) The SWPPP personnel team is not up to-date. The SWPPP still notes Mr. Riggin as a head member of the team and Mr. Riggin no longer works at the facility. The facility should update the SWPPP team to reflect changes in site personnel and responsibilities. 4) The facility is not completing and reporting adequate visual and benchmark monitoring results. Benchmark monitoring samples were only reported for Outfall 5 on the non-active Millenium Landfill parcel, the remaining were reported no discharge. Visual monitoring was only reported at Outfall 5. es from KCI Technologies show a lack of understanding of all outfall locations onsite. During today s inspection all outfalls were able to be observed. Discharges were observed in every Outfall except for Outfall 6 with no precipitation occurring during the time of inspection. There is a clear lack of effort to comply with Permit reporting requirements and conditions based upon today s inspection findings. The facility should inform the testing lab of all outfall locations to obtain proper sampling results. The facility should complete visual monitoring reports for all listed outfalls associated with industrial activities per the SWPPP. The facility should report benchmark monitoring results for all outfalls associated with industrial activities per the SWPPP. 5) The dewatering device in Basin #4 in still not being properly maintained. There is evidence of sediment build-up in the stone of the dewatering device due to established vegetation. The facility was notified to correct this violation in September 2015. The facility should implement maintenance procedures of the dewatering device in Basin #4. 6) There were no records of quarterly routine facility inspections or annual comprehensive site inspections available for review on-site. The facility should implement and document routine quarterly and annual comprehensive site inspection per Permit conditions. STATE LAW PROVIDES FOR PENALTIES FOR VIOLATIONS OF MARYLAND ENVIRONMENT ARTICLE TITLES 4, 9 FOR EACH DAY THE VIOLATION CONTINUES. THE MARYLAND DEPARTMENT OF THE ENVIRONMENT MAY SEEK PENALTIES FOR THE AFOREMENTIONED VIOLATIONS OF TITLES 4, 9 ON THIS SITE FOR EACH DAY THE VIOLATION CONTINUES. The facility should complete a corrective action report to the Department per Permit conditions as outlined in the Permit No. 12-SW Part IV- Corrective Actions. A follow-up inspection of this facility will be conducted within 14 days to verify corrections of unauthorized discharges occurring on-site and to evaluate the facility s sediment/erosion control plan. A copy of this report has been referred to the Division Chief. Page 5
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill A copy of this report will be referred to Baltimore City Sediment/Erosion Control. Any questions regarding this report can be referred to Brenden Hogan at 410-537-3978 or at brenden.hogan@maryland.gov. A copy of this report has been e-mailed to Mr. Carter of the Quarantine Road Municipal Landfill. NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 1. Does the facility have a discharge permit? [Environment Article 9-323a(1-3)] 2. Is the discharge permit current? Has facility applied for renewal? [Environment Article 9-328a(1)] 3. Is the facility as described in the current permit? Are treatment processes as described in the current permit? [COMAR 26.08.04.01.01B(4)] 4. Has notification been submitted about any new, different or increased discharges? [40 CFR Part 122 Subpart C Section 122.42.b(1-3)] 5. Is the number and location of discharge points as described in the discharge permit? [Environment Article 9-3314] 6. Has permittee submitted correct name and address of receiving waters? [40 CFR 122.21.j(3)] 7. Is the permittee meeting the compliance schedule per permit requirements? [COMAR 26.08.04.02-1.02-1A(3)] 8. Has the operator or superintendent been certified by the Board in the appropriate classification for the facility? [COMAR 26.06.01.05A(1)] 9. Are adequate records being maintained for the sampling date, time, and exact location; analysis dates and times; individual performing analysis; and analytical results? [COMAR 26.08.04.03.03B(3)(a, b, c, e)] 10. Are adequate records being maintained for the analytical methods/techniques used? [COMAR 26.08.04.03.03B(3)(d)] 11. Does the permittee retained a minimum of 3 years worth of monitoring records including raw data and original strip chart recordings; calibration and maintenance records; and reports? [COMAR 26.08.04.03.03B(1)] Evaluated No quarterly or annual facility inspections available for review. The permittee has only been reporting benchmark monitoring and visual monitoring results for Outfall 5. There are a total of seven outfalls listed on the SWPPP site map. During today's inspection discharges were observed at many of the outfalls. Page 6
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 12. Is the lab and monitoring equipment being properly calibrated and maintained? Are they keeping records to reflect this? [Environment Article 9-3313] 13. Is laboratory controls and appropriate quality assurance procedures properly operated and maintained? [40 CFR Part 122 Subpart C Section 122.41.e] 14. Has the permittee submitted the monitoring results on the proper Discharge Monitoring Report form? [COMAR 26.08.04.03.03C(1)] 15. Has the permittee submitted these results within the allotted time? [COMAR 26.08.04.03.03C(2)] 16. Are discharge monitoring reports complete and reflect permit conditions? [COMAR 26.08.04.03B(3)] 17. Is the facility being properly operated and maintained including:(a) stand-by power or equivalent provisions available, (b) adequate alarm system for power or equipment failure available, (c) all treatments units are in service,. [40 CFR Part 122 Subpart C Section 122.41.e] 18. Is sewage sludge managed correctly per permit requirements? [COMAR 26.04.06.03.03] 19. Any by-pass since last inspection? Has permittee submitted notice of any by-pass? [40 CFR Part 122 Subpart C Section 122.41.m(4)(i)(C)] 20. Any non-complying discharges experienced since last inspection? Has regulatory agency been notified? [40 CFR Part 122 Subpart C Section 122.41.l(6)] 21. Have overflows occurred since the last inspection? [COMAR 26.08.10.02A] 22. Has records of overflows been maintained at the facility for at least five years? [COMAR 26.08.10.06A-B] 23. Are flow measuring devices properly installed and operated, calibration frequency of flow meter adequate, flow measurement equipment adequate to handle expected ranges of flow? [40 CFR Part 122 Subpart C Section 122.41.e] Evaluated Evaluated Evaluated The permittee has only been reporting benchmark monitoring and visual monitoring results for Outfall 5. There are a total of seven outfalls listed on the SWPPP site map. During today's inspection discharges were observed at many of the outfalls. See findings. See findings. Page 7
Inspection Date: March 16, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 24. Are discharge monitoring points adequate for representative sampling? Do parameters and sampling frequency meet the minimum requirements? Does the permittee use the method of sample collection required by the permit? [Environment Article 9-331(4)] 25. Are analytical testing procedures approved by EPA? If alternate analytical procedures are used, proper approval has been obtained? [COMAR 26.08.01.02B(1)] 26. Has the permittee notified the Department of the name and address of the commercial laboratory? [COMAR 26.08.04.03.03A(3)] 27. Were discharges observed at the authorized outfalls? Does the facility have any unauthorized discharges to waters of the State? [Environment Article 9-322] 28. Does the discharges or receiving waters have any visible pollutants (oil sheen, grease, turbidity, foam, floating solids, color), odor, noncompliant DO concentrations, and/or noncompliant temperature ranges? [Environment Article 9-314b(1)] 29. Were discharge samples collected? [Environment Article 9-261c(1)] 30. Is the facility required to have a storm water pollution prevention plan? Has storm water pollution prevention plan been developed and implemented as required? Does storm water pollution prevention plan require modifications to prevent runoff of pollutants? [40 CFR Part 122 Subpart B Section 122.26.c(1)(I)(A-B)] 31. Are the permit conditions being met? [Environment Article 9-326a(1)] Evaluated The permittee has only been reporting benchmark monitoring and visual monitoring results for Outfall 5. There are a total of seven outfalls listed on the SWPPP site map. During today's inspection discharges were observed at many of the outfalls. See findings. See findings. See findings. See findings. Inspector: Brenden Hogan/3/16/16 brenden.hogan@maryland.gov 410-537-3978 Received by: Signature/Date Print Name Report Provided to: Douglas Carter [ ] Fax [ ] Email Douglas.Carter@baltimorecity.gov [ ] Regular Mail [ ] Certified Mail Page 8
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #1- Outfall 2A East of the leachate lagoon, discharge observed. Photo #2- Outfall 2B observed to the West of the leachate lagoon with some discharge. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #3- Sediment accumulation observed in Basin 4 at the bottom of the drainage channel. Photo #4- The dewatering device in Basin 4 has vegetation growing from it. Indicates lack of maintenance. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #5- Red/turbid discharge observed at Outfall 3. Photo #6- Basin A still has pipe stub capped causing high water. Inlet protection to Basin A still has not been repaired. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #7- Damaged inlet protection and sediment deposition to Basin A. Photo #8- Evidence of overflows from Basin A. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #9- Evidence of overflows from Basin A, note the gullying. Photo #10- Outfall 4 from Basin A, some discharge present. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #11- Erosion present at top of damaged inlet channel to Basin A. Photo #12- Silt fence controls down along the haul road with accumulated sediment and erosion. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #13- Ash runoff from the top of active cell 6 towards the haul road. Photo #14- Ash runoff from the top of active cell 6 towards the haul road. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #15- Turbid discharge at Outfall 1. Photo #16- Discharge observed at Outfall 5. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #17- Leachate observed discharging near damaged pump station near Outfall 5 on the East side of the Millenium Landfill parcel. Photo #18- Leachate discharging from ground near damaged pump station. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #19- Following flow of unauthorized leachate discharge. Photo #20- Flow of leachate leads towards monitoring well. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #21- Flow of leachate flows into the ground near monitoring well. Photo #22- Flow observed downstream of Outfall 5, no odor observed. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #23- Damaged pump near leachate storage tanks on Millenium Landfill parcel. BH, 3/16/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
Maryland Department of Environment Water Management Administration Program 1800 Washington Blvd, Baltimore, MD 21230 410-537-3510 AI ID: 13670 Inspector: Brenden Hogan Site Name: Quarantine Road Municipal Landfill County: Baltimore City Inspection Date: March 23, 2016 Start Date/Time: March 23, 2016, 11:30 AM End Date /Time: March 23, 2016, 02:00 PM Media Type(s): NPDES Industrial Stormwater Contact(s): Carroll Brown - Baltimore City Sediment/Erosion Control Douglas Carter - Acting Chief-Landfill Superintendent Dennis Peaton - Landfill Worker Joana Pei - Baltimore City DPW NPDES Industrial Stormwater Permit / Approval Numbers: 12SW0257 PAF Number: 16-2308 Site Status: Active Site Condition: Noncompliance Recommended Action: Additional Investigation Required, Refer to Others (See Findings) Inspection Reason: PAF Follow-up, Violation Follow-up Evidence Collected: Photos/Videos Taken, Visual Observation Inspection Findings: Today on March 23, 2016 a follow-up inspection was conducted for noncompliance with the Maryland General Discharge Permit for Industrial Stormwater at the Quarantine Road Municipal Landfill. During the previous inspection (see report dated 3/16/16) several violations were observed on-site during an inspection conducted at the facility as a result of a referral from the Department s Land Management Administration. Findings from the inspection were referred to Baltimore City Sediment/Erosion Control. Today s inspection was pre-arranged with the Landfill Superintendant Douglas Carter and Carroll Brown, an inspector with Baltimore City Sediment/Erosion Control. During today s inspection we were also accompanied by Joana Pei
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill (Baltimore City DPW), and Dennis Peaton (Landfill Worker-Baltimore City DPW). The weather today was sunny and warm. During today s inspection we went to the trailer on-site to review specifications for Sediment Basin A and Sediment Basin 4 per the available sediment/erosion control plans on-site prior to an inspection walkthrough. Hard copies of all current specifications/plan details for Basins A and 4 were not available for review during today s inspection. Mr. Carter stated that he would have his engineer provide copies of the plan details and e-mail them to this inspector for review later today. All accompanied this inspector for an inspection walkthrough of the facility. During the previous inspection Basin A was observed (see 3/16/16 report). Inlet protection to Basin A was observed damaged, the riser structure in Basin A remained capped and the water level in the basin was high. Along the South perimeter of Basin A there was evidence of water flow and erosion. It was thought at the time of inspection that Basin A may be overflowing at this point. During today s inspection Mr. Carter and Mr. Brown explained that there used to be a segment of diversion fence along the banks of Basin A in this area. The remnants of the fence can still be seen (see photos). The fence was most likely damaged and was allowing stormwater to drain into the basin at this point. Evidence of erosion/gullies is present along where the fence was placed at the edge of the embankment. Mr. Carter stated that this area will be stabilized. Based on this new information, it was agreed upon that Basin A was not overflowing along the South perimeter as indicated in the previous inspection report dated 3/16/16. Mr. Carter discussed with this inspector dewatering procedures for Basin A to install the dewatering device per the approved sediment/erosion control plan. The basin is still capped and does not have the approved dewatering device installed. It was explained to Mr. Carter that the water in the basin could be potentially contaminated from the ash/waste runoff from the active cell, and should not be discharged to Waters of the State. It was discussed with Mr. Carter that the water in the basin should be discharged to the sanitary sewer system with consent from the Wastewater Treatment Plant. During today s inspection the dewatering device in Basin 4 was still observed to have vegetation present indicating lack of maintenance (see photos) (see findings from 3/16/16). The haul road and face of the active cell 6 above Basin A were observed today. The ash runoff observed from the active cell on 3/16/16 is still in an exposed location to stormwater runoff (see photos). Mr. Carter stated during today s inspection that the facility will be using an excavator rather than the bobcat equipment to remove the ash/waste along the face of the slope and replace the area with appropriate cover. Silt fence controls were observed repaired along the haul road (see photos) from the previous inspection. Mr. Carter stated that the facility plans to bring in Potts & Callahan to assist with cover and erosion issues in approximately 2 weeks. All accompanied this inspector to observe the area where the leachate was actively discharging on the East side of the Millenium Landfill parcel near Outfall 5 on 3/16/16. Mr. Carter explained that the facility has been actively pumping leachate from the area and hauling it to the leachate lagoons on the active side for disposal since the discovery. During today s inspection leachate was still observed upwelling from the ground near the pump station uncontrolled (see photos). Riffles could be observed on the surface of the leachate, strong odor was present in the area. The facility has made progress on the leachate discharge by pumping and hauling, not as much leachate was observed pooled up on the ground during today s inspection (see photos) and was concentrated near the pump station. During the previous inspection the leachate discharge was observed to reach Page 2
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill a monitoring well marked 08 and was seeping into the ground. The residual stained path of the discharge was observed today (see photos). The facility has been using the portable sumps normally stationed at the lagoons to suck the leachate from the area. When the level of the leachate pooled up on the ground is too low, the portable sump becomes difficult to use. A tanker truck was observed during today s inspection hauling leachate from the area. Some leachate spillage was observed on the ground beneath the connection point of the hose and the truck (see photos). This indicates that some leachate is being released during the transfer operation. Mr. Carter was advised during today s inspection to place something beneath the leaking connection point to capture leachate drips/spills during the transfer operations. Mr. Carter stated that the facility pumps and hauls a truckload approximately every hour, the truck takes approximately 40 minutes to load. Mr. Carter stated during today s inspection that the facility plans to have the pumping system repaired and the leachate discharge under control in two weeks time. With respect to the above MDE authorization the following violations of Environment Article, Title 4 by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Sediment deposition was observed in Basin A. Inlet protection above Basin A has been damaged and sediments are exposed to stormwater runoff. Damaged inlet protection has not been addressed per the previous issuance of inspection reports. Sediments are in a position to pollute Waters of the State. The damaged inlet protection to Basin A should be addressed. Excess sediment deposits to Basin A should be mucked out and removed. Sediments should not be placed in a position to pollute Waters of the State. 2) There is no dewatering device in Basin A per the approved sediment/erosion control plan. The riser structure has been capped to repair the inlet protection to Basin A since September 2015. Work to repair the inlet structure to Basin A has not been completed. The facility should install the dewatering device in Basin A per the approved Sediment/Erosion Control Plan. The water held in Basin A could be potentially contaminated from pollutants exposed to stormwater runoff at the active cell. In order to install the proper dewatering device in Basin A per the approved Sediment/Erosion Control plan, the facility should not discharge contaminated/sediment-laden water to Waters of the State. The facility should dewater the basin to the sanitary sewer system with consent from the wastewater treatment plant. With respect to the above MDE authorization the following violations of Environment Article Title 9, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) The active leachate discharge observed on 3/16/16 is on-going. Leachate was observed welling up out of the ground near a pump station on the East side of the Millenium Landfill parcel near Outfall 5 due to malfunctioning pumping systems on-site. The facility should continue to address and prevent the active leachate discharge on-site. The facility should fix the pumping and leachate conveyance systems to prevent further releases to the environment. The discharged Page 3
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill leachate should be cleaned up, pumped, and hauled to a proper treatment and disposal facility (TSDF) immediately. 2) The facility has not been applying adequate cover per the SWPPP for the incoming ash and waste in the active cell, and as a result contaminants continue to be placed in a position likely to runoff and pollute Waters of the State. The facility should address adequate cover of exposed waste per the direction of the Department s Land Management Administration. Ash and other waste pollutants that have runoff the slopes of the active cell should be removed and placed in a position not likely to runoff and pollute Waters of the State. 3) The dewatering device in Basin #4 is still not being properly maintained. There is evidence of sediment build-up on the stone of the dewatering device due to established vegetation. This is a repeat violation. The facility should implement maintenance procedures of the dewatering device in Basin #4. 4) The facility has not been implementing the Stormwater Pollution Prevention Plan (SWPPP) per Permit conditions. SWPPP documentation/records violations from the inspection report dated 3/16/16 are outstanding. The facility should implement the SWPPP in accordance to Permit conditions and complete all required routine facility inspections and monitoring. STATE LAW PROVIDES FOR PENALTIES FOR VIOLATIONS OF MARYLAND ENVIRONMENT ARTICLE TITLES 4, 9 FOR EACH DAY THE VIOLATION CONTINUES. THE MARYLAND DEPARTMENT OF THE ENVIRONMENT MAY SEEK PENALTIES FOR THE AFOREMENTIONED VIOLATIONS OF TITLES 4, 9 ON THIS SITE FOR EACH DAY THE VIOLATION CONTINUES. This report serves as a reminder that the facility should complete and submit a corrective action report to the Department per Permit conditions as outlined in the Permit No. 12-SW Part IV- Corrective Action. Plan details provided for Sediment Basins A and 4 will be reviewed post-inspection. A follow-up inspection of this facility will be conducted in approximately 14 days. A copy of this report has been referred to the Division Chief. Any questions regarding this report can be referred to Brenden Hogan at 410-537-3978 or at brenden.hogan@maryland.gov. A copy of this report has been e-mailed to Mr. Carter of the Quarantine Road Municipal Landfill. Page 4
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 1. Does the facility have a discharge permit? [Environment Article 9-323a(1-3)] 2. Is the discharge permit current? Has facility applied for renewal? [Environment Article 9-328a(1)] 3. Is the facility as described in the current permit? Are treatment processes as described in the current permit? [COMAR 26.08.04.01.01B(4)] 4. Has notification been submitted about any new, different or increased discharges? [40 CFR Part 122 Subpart C Section 122.42.b(1-3)] 5. Is the number and location of discharge points as described in the discharge permit? [Environment Article 9-3314] 6. Has permittee submitted correct name and address of receiving waters? [40 CFR 122.21.j(3)] 7. Is the permittee meeting the compliance schedule per permit requirements? [COMAR 26.08.04.02-1.02-1A(3)] 8. Has the operator or superintendent been certified by the Board in the appropriate classification for the facility? [COMAR 26.06.01.05A(1)] 9. Are adequate records being maintained for the sampling date, time, and exact location; analysis dates and times; individual performing analysis; and analytical results? [COMAR 26.08.04.03.03B(3)(a, b, c, e)] 10. Are adequate records being maintained for the analytical methods/techniques used? [COMAR 26.08.04.03.03B(3)(d)] 11. Does the permittee retained a minimum of 3 years worth of monitoring records including raw data and original strip chart recordings; calibration and maintenance records; and reports? [COMAR 26.08.04.03.03B(1)] 12. Is the lab and monitoring equipment being properly calibrated and maintained? Are they keeping records to reflect this? [Environment Article 9-3313] 13. Is laboratory controls and appropriate quality assurance procedures properly operated and maintained? [40 CFR Part 122 Subpart C Section 122.41.e] 14. Has the permittee submitted the monitoring results on the proper Discharge Monitoring Report form? [COMAR 26.08.04.03.03C(1)] See findings. See findings. Page 5
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 15. Has the permittee submitted these results within the allotted time? [COMAR 26.08.04.03.03C(2)] 16. Are discharge monitoring reports complete and reflect permit conditions? [COMAR 26.08.04.03B(3)] 17. Is the facility being properly operated and maintained including:(a) stand-by power or equivalent provisions available, (b) adequate alarm system for power or equipment failure available, (c) all treatments units are in service,. [40 CFR Part 122 Subpart C Section 122.41.e] 18. Is sewage sludge managed correctly per permit requirements? [COMAR 26.04.06.03.03] 19. Any by-pass since last inspection? Has permittee submitted notice of any by-pass? [40 CFR Part 122 Subpart C Section 122.41.m(4)(i)(C)] 20. Any non-complying discharges experienced since last inspection? Has regulatory agency been notified? [40 CFR Part 122 Subpart C Section 122.41.l(6)] 21. Have overflows occurred since the last inspection? [COMAR 26.08.10.02A] 22. Has records of overflows been maintained at the facility for at least five years? [COMAR 26.08.10.06A-B] 23. Are flow measuring devices properly installed and operated, calibration frequency of flow meter adequate, flow measurement equipment adequate to handle expected ranges of flow? [40 CFR Part 122 Subpart C Section 122.41.e] 24. Are discharge monitoring points adequate for representative sampling? Do parameters and sampling frequency meet the minimum requirements? Does the permittee use the method of sample collection required by the permit? [Environment Article 9-331(4)] 25. Are analytical testing procedures approved by EPA? If alternate analytical procedures are used, proper approval has been obtained? [COMAR 26.08.01.02B(1)] 26. Has the permittee notified the Department of the name and address of the commercial laboratory? [COMAR 26.08.04.03.03A(3)] 27. Were discharges observed at the authorized outfalls? Does the facility have any unauthorized discharges to waters of the State? [Environment Article 9-322] Evaluated Evaluated Evaluated See findings. See findings. Leachate discharge on-site in on-going. See report findings 3-16-16. See findings. See findings. Page 6
Inspection Date: March 23, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 28. Does the discharges or receiving waters have any visible pollutants (oil sheen, grease, turbidity, foam, floating solids, color), odor, noncompliant DO concentrations, and/or noncompliant temperature ranges? [Environment Article 9-314b(1)] 29. Were discharge samples collected? [Environment Article 9-261c(1)] 30. Is the facility required to have a storm water pollution prevention plan? Has storm water pollution prevention plan been developed and implemented as required? Does storm water pollution prevention plan require modifications to prevent runoff of pollutants? [40 CFR Part 122 Subpart B Section 122.26.c(1)(I)(A-B)] 31. Are the permit conditions being met? [Environment Article 9-326a(1)] Evaluated See findings. See findings. See findings. Inspector : Received by: Signature/Date Brenden Hogan/3/23/16 brenden.hogan@maryland.gov 410-537-3978 Print Name Report Provided to: Douglas Carter [ ] Fax [ ] Email Douglas.Carter@baltimorecity.gov [ ] Regular Mail [ ] Certified Mail Page 7
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #1- Sediment deposition still present in Basin 4. Photo #2- Vegetation still present on dewatering device of Basin 4. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #3- Bank of Basin A where overflowing was believed to be occurring, old section of diversion fence present. Photo #4- Old diversion fence segment along Basin A. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #5- The unaddressed ash runoff from the top of the active cell 6. Photo #6- The repaired silt fence along the haul road. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #7- Active leachate discharge on the Millenium Landfill parcel. Photo #8- Active leachate discharge on the Millenium Landfill parcel. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #9- Leachate discharge path from the source to the monitoring well. Photo #10- Where the leachate flowed towards the monitoring well. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #11- Evidence of leachate spilled from pumping and transfer operations to the truck. BH, 3/23/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
Maryland Department of Environment Water Management Administration Program 1800 Washington Blvd, Baltimore, MD 21230 410-537-3510 AI ID: 13670 Inspector: Brenden Hogan Site Name: Quarantine Road Municipal Landfill County: Baltimore City Inspection Date: April 14, 2016 Start Date/Time: April 14, 2016, 12:30 PM End Date /Time: April 14, 2016, 03:00 PM Media Type(s): NPDES Industrial Stormwater Contact(s): Douglas Carter - Landfill Superintendent Vivaldi Nguyen - Engineer Joana Pei - Baltimore City DPW NPDES Industrial Stormwater Permit / Approval Numbers: 12SW0257 Site Status: Active Site Condition: Noncompliance Recommended Action: Additional Investigation Required, Refer to Others (See Findings) Inspection Reason: Initial Quarterly, Follow-up (Non-) Evidence Collected: Photos/Videos Taken, Visual Observation Inspection Findings: Today on April 14, 2016 an unannounced follow-up inspection was conducted for noncompliance with the Maryland General Discharge Permit for Industrial Stormwater at the Quarantine Road Municipal Landfill. During today s inspection I met with Doug Carter (Landfill Superintendent), Joana Pei (Baltimore City DPW), and Vivaldi Nguyen (Engineer). The weather conditions today were sunny and warm. During today s inspection Mr. Carter accompanied me for an inspection walkthrough of the facility. Mr. Carter was also present for a records review of the site s Stormwater Pollution Prevention Plan (SWPPP) and General Discharge Permit. Since the previous inspections the facility has been working to get back into compliance (see inspection findings from 3/23/16 and 3/16/16). A corrective action report was provided to this inspector by the facility on 3/26/16 for previous violations identified on 3/23/16.
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill During the previous inspection the leachate pumps on the Millenium parcel of the landfill were still not functional. Leachate was observed pooled up near one of the pump houses and the facility was pumping and hauling leachate every day from the area to the lagoons on the other side of the landfill for disposal. Mr. Carter stated that between 6-8 loads were hauled each day. During today s inspection Mr. Carter took me to the area where the unauthorized leachate discharge was previously observed. The leachate was no longer observed pooled up in the area. The well from which the leachate discharge had occurred was observed open. Leachate could be observed in the well. The area around the pump hose and well towards the monitoring well marked 08 is stained from the leachate discharge that occurred. Mr. Carter stated that he has been raking up and disposing of the stained material and has been applying lime to the area (see photos). Mr. Carter stated that KCI Technologies is on-site today sampling monitoring wells around the landfill. It was requested during today s inspection that the facility provide the Department with the monitoring well date from 08 where the discharge occurred as soon as possible. The leachate storage tanks on the Millenium landfill parcel were observed. The new pump system was observed to be functional during today s inspection (see photos). Both of the pumps are on automatic mode. Mr. Carter stated that the pumping system on the Millenium parcel was fixed on Tuesday 4/12/16. The pump monitoring screen was reviewed at the trailer, only pump station 1 on the active side was observed to be in need of repair during today s inspection. Mr. Carter stated the facility is still working on fixing this pumping station. The active face of Cell 6 was observed during today s inspection. The area upslope of Basin A and along the haul road was also observed. Mr. Carter stated that the ash that was previously observed along the face of the slope above Basin A was removed on 3/25/16 and 3/26/16. Mr. Carter had sent pictures of the completed work to this inspector. The ash was removed from the face and taken up to the top of the active cell and buried. Mr. Carter stated that Potts & Callahan has been on-site to provide adequate cover for the waste on the active cell. Cover application to prevent exposed waste was much improved from previous inspections today. It was explained to Mr. Carter that the facility should still apply cover to the waste per the direction of the Department s Land Management Administration. Mr. Carter stated during today s inspection that the Department s Land Management Administration has arranged for a meeting at the facility one week from today. Site conditions for Basin A and Basin 4 remain the same since the previous inspection. The riser structure in Basin A is still missing a dewatering device per the approved sediment/erosion control plan and is capped. The inlet to Basin A remains damaged (see photos). The dewatering device in Basin 4 remains vegetated indicating sediment build-up (see photos). Sediment was observed accumulated in both basins. Mr. Carter explained that the facility has met with a new contractor to get a bid to finally complete the work on these outstanding violations. This meeting was noted in a recent facility inspection report. The contractor is identified as Monumental Paving, and the report notes that the facility engineer Vivaldi Nguyen met with them on 3/28/16 to discuss the proposed work of the smart ditch and Basin A repairs. Mr. Carter explained during today s inspection that the facility has reorganized the SWPPP team and individual responsibilities for implementing the SWPPP. Mr. Carter was able to show new routine facility inspection forms that have been developed. The first inspection form was completed by Joana Pei on 3/28/16. New non-stormwater discharge evaluation forms were also observed. A non-stormwater evaluation was completed by Joana Pei on 3/30/16. Ms. Pei stated that this will be done on a more frequent quarterly basis. The non-stormwater discharge evaluation form indicates checks of every outfall at the facility. No new visual monitoring reports were available for Page 2
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill review during today s inspection. Ms. Pei stated that the facility will be using the standard MDE form in the Permit No. 12-SW for visual monitoring. Ms. Pei stated during today s inspection that the facility collected samples for benchmark monitoring reporting on 3/28/16 and on 4/7/16. During today s inspection Mr. Carter was able to provide a copy of the approved sediment/erosion control plan for review for the cell 6 leachate conveyance system improvements at the Quarantine Road Landfill. The plan was approved on 9/5/14 by Baltimore City Sediment/Erosion Control. Mr. Carter and Mr. Nguyen stated that the dewatering device added to Basin A was an addendum to the original sediment/erosion control plan. It was requested that this sediment/erosion control plan be provided in electronic format to this inspector along with the approved dewatering device detail in Basin A. The approved details will be reviewed postinspection once provided. With respect to the above MDE authorization the following violations of Environment Article Title 4, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) Sediment deposition was observed in Basin A. Inlet protection above Basin A has been damaged and sediments are exposed to stormwater runoff. Damaged inlet protection has not been addressed per the previous issuance of inspection reports. Sediments are in a position to pollute Waters of the State. The damaged inlet protection to Basin A should be addressed. Excess sediment deposits to Basin A should be mucked out and removed. Sediments should not be placed in a position to pollute Waters of the State. 2) There is no dewatering device in Basin A per the approved sediment/erosion control plan. The riser structure has been capped to repair the inlet protection to Basin A since September 2015. Work to repair the inlet structure to Basin A has not been completed. The facility should install the dewatering device in Basin A per the approved Sediment/Erosion Control Plan. The water held in Basin A could be potentially contaminated from pollutants exposed to stormwater runoff at the active cell. In order to install the proper dewatering device in Basin A per the approved Sediment/Erosion Control plan, the facility should not discharge contaminated/sediment-laden water to Waters of the State. The facility should dewater the basin to the sanitary sewer system with consent from the wastewater treatment plant. With respect to the above MDE authorization the following violations of Environment Article Title 9, by the Quarantine Road Municipal Landfill were observed this date with corrections needed immediately: 1) The dewatering device in Basin 4 is still not being properly maintained. There is evidence of sediment build-up on the stone of the dewatering device due to established vegetation. This is a repeat violation. The facility should implement maintenance procedures of the dewatering device in Basin 4. 2) No updated visual monitoring reports were available for review during today s inspection. The facility should complete visual monitoring in accordance to Permit conditions and document with the SWPPP. Page 3
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill *The facility should continue to apply cover to the waste on the active cell of the landfill per the direction of the Department s Land Management Administration.* *The facility should provide the Department with monitoring well data for the monitoring well 08 near the area of the unauthorized leachate discharge.* STATE LAW PROVIDES FOR PENALTIES FOR VIOLATIONS OF MARYLAND ENVIRONMENT ARTICLE TITLES 4, 9 FOR EACH DAY THE VIOLATION CONTINUES. THE MARYLAND DEPARTMENT OF THE ENVIRONMENT MAY SEEK PENALTIES FOR THE AFOREMENTIONED VIOLATIONS OF TITLES 4, 9 ON THIS SITE FOR EACH DAY THE VIOLATION CONTINUES. A follow-up inspection of this facility will be conducted in approximately 30 days. A copy of this report has been referred to the Division Chief. Findings from today s inspection were discussed with the Department s Land Management Administration. Any questions regarding this report can be referred to Brenden Hogan at 410-537-3978 or at brenden.hogan@maryland.gov. A copy of this report has been e-mailed to Mr. Carter of the Quarantine Road Municipal Landfill. NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 1. Does the facility have a discharge permit? [Environment Article 9-323a(1-3)] 2. Is the discharge permit current? Has facility applied for renewal? [Environment Article 9-328a(1)] 3. Is the facility as described in the current permit? Are treatment processes as described in the current permit? [COMAR 26.08.04.01.01B(4)] 4. Has notification been submitted about any new, different or increased discharges? [40 CFR Part 122 Subpart C Section 122.42.b(1-3)] 5. Is the number and location of discharge points as described in the discharge permit? [Environment Article 9-3314] 6. Has permittee submitted correct name and address of receiving waters? [40 CFR 122.21.j(3)] 7. Is the permittee meeting the compliance schedule per permit requirements? [COMAR 26.08.04.02-1.02-1A(3)] The facility has begun to implement routine inspections per Permit conditions. New monitoring results are not yet available for review. Page 4
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 8. Has the operator or superintendent been certified by the Board in the appropriate classification for the facility? [COMAR 26.06.01.05A(1)] 9. Are adequate records being maintained for the sampling date, time, and exact location; analysis dates and times; individual performing analysis; and analytical results? [COMAR 26.08.04.03.03B(3)(a, b, c, e)] 10. Are adequate records being maintained for the analytical methods/techniques used? [COMAR 26.08.04.03.03B(3)(d)] 11. Does the permittee retained a minimum of 3 years worth of monitoring records including raw data and original strip chart recordings; calibration and maintenance records; and reports? [COMAR 26.08.04.03.03B(1)] 12. Is the lab and monitoring equipment being properly calibrated and maintained? Are they keeping records to reflect this? [Environment Article 9-3313] 13. Is laboratory controls and appropriate quality assurance procedures properly operated and maintained? [40 CFR Part 122 Subpart C Section 122.41.e] 14. Has the permittee submitted the monitoring results on the proper Discharge Monitoring Report form? [COMAR 26.08.04.03.03C(1)] 15. Has the permittee submitted these results within the allotted time? [COMAR 26.08.04.03.03C(2)] 16. Are discharge monitoring reports complete and reflect permit conditions? [COMAR 26.08.04.03B(3)] 17. Is the facility being properly operated and maintained including:(a) stand-by power or equivalent provisions available, (b) adequate alarm system for power or equipment failure available, (c) all treatments units are in service,. [40 CFR Part 122 Subpart C Section 122.41.e] 18. Is sewage sludge managed correctly per permit requirements? [COMAR 26.04.06.03.03] 19. Any by-pass since last inspection? Has permittee submitted notice of any by-pass? [40 CFR Part 122 Subpart C Section 122.41.m(4)(i)(C)] Evaluated Visual and benchmark monitoring records are not available for review at this time. Evaluated Evaluated Evaluated Info The facility has sampled for the benchmark monitoring requirement of the Permit for the first quarter and second quarter of 2016. The results are not yet available for review through NetDMR. Page 5
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill NPDES Industrial Stormwater- Inspection Checklist Inspection Item Status Comments 20. Any non-complying discharges experienced since last inspection? Has regulatory agency been notified? [40 CFR Part 122 Subpart C Section 122.41.l(6)] 21. Have overflows occurred since the last inspection? [COMAR 26.08.10.02A] 22. Has records of overflows been maintained at the facility for at least five years? [COMAR 26.08.10.06A-B] 23. Are flow measuring devices properly installed and operated, calibration frequency of flow meter adequate, flow measurement equipment adequate to handle expected ranges of flow? [40 CFR Part 122 Subpart C Section 122.41.e] 24. Are discharge monitoring points adequate for representative sampling? Do parameters and sampling frequency meet the minimum requirements? Does the permittee use the method of sample collection required by the permit? [Environment Article 9-331(4)] 25. Are analytical testing procedures approved by EPA? If alternate analytical procedures are used, proper approval has been obtained? [COMAR 26.08.01.02B(1)] 26. Has the permittee notified the Department of the name and address of the commercial laboratory? [COMAR 26.08.04.03.03A(3)] 27. Were discharges observed at the authorized outfalls? Does the facility have any unauthorized discharges to waters of the State? [Environment Article 9-322] 28. Does the discharges or receiving waters have any visible pollutants (oil sheen, grease, turbidity, foam, floating solids, color), odor, noncompliant DO concentrations, and/or noncompliant temperature ranges? [Environment Article 9-314b(1)] 29. Were discharge samples collected? [Environment Article 9-261c(1)] 30. Is the facility required to have a storm water pollution prevention plan? Has storm water pollution prevention plan been developed and implemented as required? Does storm water pollution prevention plan require modifications to prevent runoff of pollutants? [40 CFR Part 122 Subpart B Section 122.26.c(1)(I)(A-B)] 31. Are the permit conditions being met? [Environment Article 9-326a(1)] Info Evaluated Evaluated The facility has sampled for the benchmark monitoring requirement of the Permit for the first quarter and second quarter of 2016. The results are not yet available for review through NetDMR. See findings. See findings. See findings. Page 6
Inspection Date: April 14, 2016 Site Name: Quarantine Road Municipal Landfill Inspector: Brenden Hogan/4/14/16 brenden.hogan@maryland.gov 410-537-3978 Received by: Signature/Date Print Name Report Provided to: Douglas Carter [ ] Fax [ ] Email Douglas.Carter@baltimorecity.gov [ ] Regular Mail [ ] Certified Mail Page 7
BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #1- Area where the leachate discharge occurred. The open leachate well is exposed. Photo #2- Area where the leachate discharge occurred. The open leachate well is exposed. BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #3- The ground is stained from the previous leachate discharge. Photo #4- Stained ground being raked up. Lime applied to the ground where the leachate discharge occurred. BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #5- New pump in place for the leachate conveyance system. Photo #6- Screen on the Millenium parcel showing the pumping systems on automatic mode. BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #7- Ash removed from the face of active cell 6. Photo #8- Damaged inlet channel remains to Basin A. Basin A remains capped. BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257
BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257 Photo #9- Basin 4 with sediment accumulation- dewatering device remains vegetated. BH, 4/14/16, Baltimore City, Quarantine Road Municipal Landfill, 12SW0257