02-04-11 April 2, 2013 Mr. Carl Simmons Two Pines Landfill 100 Two Pines Drive North Little Rock, AR 72117 RE: Quarterly Inspection; AFIN 60-00438; Permit Number 0163-S1-R3 Dear Mr. Simmons: On March 25, 2013, I conducted an inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at (501) 682-0599 or [email protected]. Sincerely, Charles Stringer, ADEQ Inspector Solid Waste Management Division CC: Bryan Leamons, Engineer Supervisor, Solid Waste Division Maria Matoska, Engineer, Solid Waste Division Attachment Document ID 070871
Transcript
02-04-11
April 2, 2013 Mr. Carl Simmons Two Pines Landfill 100 Two Pines Drive North Little Rock, AR 72117 RE: Quarterly Inspection; AFIN 60-00438; Permit Number 0163-S1-R3 Dear Mr. Simmons: On March 25, 2013, I conducted an inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at (501) 682-0599 or [email protected]. Sincerely,
X 411(p) Proper wet weather repairs See Category 2 Comment page.
411(b) Operations by licensed on-site personnel at all times
411(d) Waste spread and compacted as unloaded
X 411(g) Litter control provisions maintained See Category 2 Comment page.
414(a) Disease vectors controlled
Arkansas Department of Environmental Quality
Solid Waste Management Division Class 1 Landfill Inspection
Category 2 (continued)
Regulation Item Description Comments
X 427 Surface Water Controls See Category 2 Comment page.
411(h)(1) Contouring prevents surface water flowing into or through waste
418(a)(b) Run-on/off control system present and adequate
411(h)(2) Surface water control prevents off-site sediment accumulation
411(i);427(f) Adequate maintenance of intermediate/final cover vegetation
415 Gas monitoring program
411(o) Leachate leaks or evidence of leachate seepage
426 Survey controls
429 Leachate collection system
420 Liquid Restrictions
X Depicts Violation Category 3 R (Repeat Violation)
Regulation Item Description Comments 412 Implementation of hazardous/unauthorized waste exclusion plan
X 413(a)(b) Satisfactory daily/alternative cover See Category 3 Comment page.
413(c) Satisfactory intermediate cover
416(b),411(f)(4) Open burning prohibited
419 Cause discharge/leachate discharge leaving landfill
411(f)(3),419(a)(4) Depositing waste in standing water prohibited
X 411(o) Erosion or other cover defects resulting in exposed refuse See Category 3 Comment page.
309(c) Overfill/Off lined area
Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 10/24/2012
423(b) Date of last engineering report 3/29/2012 428 Liner construction in progress Yes/No No Notice of liner construction Yes/No n/a Third party CQA on-site during construction Yes/No n/a
412(a) Date of last random inspection for unauthorized waste 3/20/2013 Total # for month February - 1 415, 421(e) Date of last quarterly methane monitoring 3/15/2013 Detection level 0 415(a) Explosive gas records current? Yes/No Yes
421(g),412(a)(2),701 Date of last special waste received 3/25/2013 Disposal location WF Cell 6 421(d) Previous quarter waste received 115,583 Tons 4th Qtr 2012 427(c) Surface water DMR records current? Yes/No Yes
Fayetteville Shale Related Yes/No Yes Fayetteville Shale Violation Yes/No No Violation
Operator Name & Number
Jermaine Thomas -002821
Signature of Inspector
Exit Interview Conducted with Damon Sanford - 003505 Method On Site Date 3/25/2013 Time 14:00
Class 1Form 7/1/2012 For ADEQ Use Only
Site Name Two Pine Class 1 – Waste Management AFIN 60-00438 Permit Number 0163-S1-R3
Category 2 Comments Reg.22.411- General Operating Requirements (Proper wet weather repairs) (p) Wet Weather Repairs - Due care shall be exercised in performing repairs during wet weather conditions to prevent the creation of additional cover defects. Prompt temporary measures shall be implemented in such cases until permanent repairs and remedies can be implemented. Comment: A dirt truck was driven on the western slope of the active landfill during a repair attempt. Tire ruts were noted on the cover system that were approximately 2 feet deep. See Photos 1 & 2. Reg.22.411- General Operating Requirements (Litter control provisions maintained) (g) Litter Control - Litter control provisions shall be maintained at all times. If daily or more frequent cover does not control on and off site litter, other methods may be required, such as, but not limited to litter fences and litter crews. Comment: Litter was noted throughout the newer landfill area. No litter fences were noted in the active fill area which is also a violation of Permit Condition #24 of the facility permit: “24. Litter control fences shall be provided in the active fill area for the control of blowing litter. Other litter control measures shall be implemented, if necessary, to confine litter to the smallest practicable extent and prevent litter from leaving the site.” Additionally, the coform absorbant material stockpiled near the liquid bulking pit is easily transported by winds and no measures are in place to prevent it from blowing out of the solidification area. See photos 3 through 10. Reg.22.427- Surface Water Control (Surface Water Controls) (b) Surface Water Control Requirements - Design of permanent and temporary drainage and runoff facilities and structures shall be documented in the operating or design narrative. Unless approved by the Department each facility shall be designed with a positive means of runoff and sedimentation control such as a sedimentation pond through which runoff from disturbed areas is routed. Runoff from active portions of the working face that has contacted the waste shall be considered leachate and shall be managed accordingly. Comment: The areas near the working face (recent working face areas) do not have a positive means of run-off because they are improperly graded, allowing water to pool and stand in several places. Because of the cover issues, flagging, tracking, etc…, all run-off and standing water within the active portion of the landfill has been in contact with waste and should be handled as leachate when correcting this issue. Additionally, the facility stormwater ditches have silting issues and require maintenance. See photos 8, 11 through 14, & 21. Date
3/25/2013
Signature of Inspector
Page
3
Category 3 Comments Page7/1/2012 For ADEQ Use Only
Arkansas Department of Environmental Quality
Solid Waste Management Division Comments Page
Site Name Two Pine Class 1 – Waste Management AFIN 60-00438 Permit Number 0163-S1-R3
Category 3 Comments Reg.22.413- Cover Material Requirements (Satisfactory daily/alternative cover) (a) Daily Cover- Except as provided in paragraph (d) of this section, the owners or operators of all Class 1 Landfills must cover disposed solid waste with six (6) inches of earthen material at the end of each operating day, or at more frequent intervals if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging and to limit the generation of leachate. (b) Alternative Cover Materials - Alternative cover materials of an alternative thickness (other than at least six inches of earthen material) may be approved by the Director, either through individual requests or through generalized Department approval upon demonstration that the alternative material and thickness controls disease vectors, fires, odors, blowing litter, and scavenging without presenting a threat to human health and the environment. Comment: (a) In the areas surrounding the working face, areas that have been recent working faces, a significant amount of waste is exposed due inadequate daily cover. In some areas it appeared as if sawdust or rice hulls had been used as cover. See photos 11& 12, 15 through 22. (b) The facility is not following the alternative daily cover plan (Doc. ID# 63441) as was approved by the Department on 11/20/2012 (Doc. ID#63477). This plan stated that the working face would be covered by 6 inches of earthen material at least weekly, however due to the large amount of exposed waste throughout the area, this has not been occurring as required. Additionally, the approval of this alternative cover plan granted the facility a 60 day trial in which frequent inspections of the tarp and its efficacy as cover were to be documented and summarized in a report that would be sent to the Department for final approval. As of the date of this inspection the required documentation has not been received by the Department and the tarps have been in use for over 90 days. Reg.22.411- General Operating Requirements (Erosion or other cover defects resulting in exposed refuse) (o) Cover Maintenance - The owner or operator shall be responsible for maintaining the cover system integrity and shall promptly repair erosion, washout, tracking, or other defects that result in exposed refuse in either daily or intermediate cover, or exposure of the barrier system of the final cover. Areas of leachate seepage, or areas exhibiting evidence of leachate seepage such as staining and discoloration of the cover system shall also be promptly repaired. Comment: Waste was exposed due to erosion and tracking on the northern slope of the active cell. See photos 23 through 26. Also, soil slumping is occurring on the slopes of the older landfill. See photo 29.
Date
3/25/2013
Signature of Inspector
Page
4
Category 3 Comments Page7/1/2012 For ADEQ Use Only
Arkansas Department of Environmental Quality
Solid Waste Management Division Comments Page
Site Name Two Pine Class 1 – Waste Management AFIN 60-00438 Permit Number 0163-S1-R3
Additional Comments The current bulking pad does not meet the design requirements or plan approved by the Department on 11/9/2012 (Xref Doc# 63440). As of this inspection, no date had been selected by the facility for construction. However, the bulking tanks have been constructed and delivered to the site. See photos 27 & 28. Damon Sanford, Facility Operations Manager, was with me as I conducted this inspection.
