02-04-11
November 15, 2013 Robert Hendrix Craighead SWDA P.O. Box 16777 Jonesboro, AR 72401 RE: Quarterly Inspection; AFIN 16-00199; Permit Number 0254-S1-R4. Dear Mr. Hendrix, On November 8, 2013, I conducted a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Regulation 22, and the above-referenced permit. A copy of the inspection report is enclosed for your records. Please refer to the attached inspection report to note the specific allegations. A written response for the noted allegations, describing the corrective action taken or to be taken, must be submitted to my attention at the address listed below within thirty (30) days from the date hereof. Failure to submit the written response shall be construed as an admission of any allegations. Any items noted that are neglected and/or persistent may warrant formal enforcement action. If I can be of any further assistance, feel free to contact me at (501) 682-0604. Sincerely,
Lori Burke, ADEQ Inspector Solid Waste Management Division Attachment
Document ID 074717
Site Name Legacy Landfill County Craighead AFIN 16-00199
Facility Address Hwy 1 south of Jonesboro Phone Number 870-972-6353 Permit Number 0254-S1-R4
Permittee Address Craighead SWDA, P.O. Box 16777, Jonesboro AR 72401 E-Mail Address [email protected] PDS # 074717
Date 11/8/2013 Entry Time 6:20 AM Exit Time 11:30 AM
Regulation 22 – Operational Standards X Depicts Violation Category 1 R Repeat Violation
Regulation Item Description Comments 411(l) Adequate employee facilities
421(a)(b) Record keeping meets requirements specified by regulations
417 Access requirements
411(j) Adequate provisions for backup equipment
421(d) Waste receipt records, ticket system maintained
411(k) Telephone system & written emergency response plan on site
423(b) Annual compliance inspection by registered professional engineer
422 Facility implements operating plan and narrative
421(f) Leachate disposal/recirculation records
421(g),701 Special waste disposal and procedures records
X Depicts Violation Category 2 R Repeat Violation
Regulation Item Description Comments R 411(a) Operations in accordance with permit documents See Category 2 Comments page
417(c) Adequate all weather operational roads
411(c) Smallest practical area, unloading supervised, single working face
411(e) Salvage operations meet approved conditions
411(f)(1) Scavenging of waste prohibited
411(p) Proper wet weather repairs
411(b) Operations by licensed on-site personnel at all times
411(d) Waste spread and compacted as unloaded
411(g) Litter control provisions maintained
414(a) Disease vectors controlled
Arkansas Department of Environmental Quality
Solid Waste Management Division Class 1 Landfill Inspection
RegulaR 427
411(h)
418(a)
R 411(h)
R 411(i);4
415
X 411(o
426
X 429
420
X Depicts VioR (Repeat Vio
Regula 412
R 413(a)
R 413(c
416(b),41
419
411(f)(3),41
411(o
309(c
421(a)(8), 120423(b)
428 412(a)
415, 421(e421(g),412(a)(2
421(d) 427(c)
Fayetteville S Operator Na
Exit Interview
Class 1Form 7/1/
ation 7 Surface W)(1) Contourin)(b) Run-on/of
)(2) Surface w27(f) Adequate
5 Gas monito) Leachate 6 Survey co9 Leachate 0 Liquid Re
olation olation) ation 2 Implemen)(b) Satisfactoc) Satisfacto1(f)(4) Open bur
9 Cause dis19(a)(4) Depositingo) Erosion oc) Overfill/O
03(k) Date of lasDate of lasLiner consDate of las
e) Date of las2),701 Date of las
Previous qSurface wa
Shale Related
me & Number
w Conducted with
/2012
ItemWater Controls ng prevents surface ff control system pr
water control prevenmaintenance of int
toring program leaks or evidence of
ontrols collection system
estrictions
Item
ntation of hazardousory daily/alternativeory intermediate covrning prohibited charge/leachate discg waste in standing r other cover defect
Off lined area
st groundwater monst engineering reporstruction in progressst random inspectionst quarterly methanest special waste receiquarter waste receivater DMR records c
Yes/No No
Robert Hendrix 0
h Angela Sparks /
m Description
water flowing into oesent and adequate
nts off-site sediment ermediate/final cove
f leachate seepage
m Description
s/unauthorized wast cover
ver
charge leaving landwater prohibited
ts resulting in expos
nitoring report rt s Yes/No Nn for unauthorized we monitoring ived
ved current?
Fayetteville Sh
00336
Robert Hendrix
Cate
or through waste
accumulation er vegetation
Cate
te exclusion plan
fill
ed refuse
Regulat 1/24/2013
3/30/2013 NO Notice of linwaste 11/6/2013
9/19/2013 11/7/2013 Yes/No
hale Violation Ye
Method O
For ADEQ
egory 2 (continu
See Category 2 co
See Category 2 co
See Category 2 co
See Category 2 co
See Category 2 co
gory 3
See Category 3 co
See Category 3 co
tion 22 - Reco
ner construction Total # foDetectionDisposal lTons
Yes es/No No
Signatur
On site
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omments page
omments page
omments page
omments page
omments page
omments page
omments page
ords
Yes/No Yes Tor month 22 n level location Cell 4, U
Class 1-
Violation
re of Inspector
Date
Commen
Commen
Third party CQA o
415(a) ExpUnit 6 -17,354.15Ton C
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Class 4-10,100.86To
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urrent? Yes/No
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Site Name
Reg.22.411 (a) plans and opera Comments: Ttime of the insp Reg. 22.427-Suminimize erosio Comments: Twas waste note Reg.22.411 Genat all landfill, sblankets, and mdescribed in the Comments: T Reg. 22.427 – exposed slopes erosion of the c Comments: Aprevent erosio
Date
1
Category 2 Commen
Legacy Landfi
General Operating Rating plans and narra
he facility was not hpection water was b
urface Water Controlson. In areas where fl
here were no adequed in the storm wate
neral Operating Requoil stockpile, and bor
matting, gravel filter be operating narrative
he surface water co
Surface Water Contrshall be seeded or s
cover system. The na
At the time of inspecn. This lack of veget
1/8/2013
nts Page7/1/2012
ill
Requirements (Operatative.
handling surface wabeing pumped from
s (Surface Water Conflow quantity and velo
uate BMP’s maintainer ditches. This ero
uirements ( Surface wrrow site areas. Temberms, check dams, re, and shall be includ
ntrol ditches on all
rol (Final and Interimstabilized if it is anti
arrative shall also des
ction, the bottom 1/3tation violation has
Sig
tions in accordance w
ater and sediment inthe approved sedim
ntrols) (d) Erosion Cocity warrant, rip rap
ned to minimize erosion and BMP’s vio
water control preventmporary and permaneriprap, sediment pondded in the permit plan
sides of the landfill
m Slope Stabilizationicipated that these slscribe vegetative mai
3 of all slopes lackedbeen noted since th
gnature of Inspec
Arkansa
AFIN
Categowith permit document
n accordance with thmentation pond into
Control- The design shp, gabions, revetment
osion on all slopes tholation has been note
ts off-site sediment acent seeding, grading, ds, and other best mans as appropriate.
had a large amount
n) (f) - The operatingopes will not be distintenance procedures
d vegetative cover ahe 1st quarter 2012.
ctor
For AD
as Departm Solid Waste Com
16-00199
ory 2 Commets) Conformance with
he approved plans. an on-site ditch. See
hall also include bermts, or other protection
hroughout the landfied since the 1st quar
ccumulation) (h) (2) Idiking, terracing, div
anagement practices f
t of sediment accum
g narrative shall descturbed for more thans and shall provide th
nd has not received See photos 15-20
DEQ Use Only
ment of Envie Managememments Page
Permit Num
ents h permit documents-
Surface water was be Photos 1-2
ms, swales, benches, n shall be provided.
fill. Additionally, exrter 2012. See Ph
Install, construct, repversion ditches, silt ffor the site shall be in
mulated and exposed
cribe seeding and son one growing seasonhat vegetation shall b
d waste for more tha
ironmental nt Division e
mber 02
All operations at the
being routed throug
downchutes and othe
xposed waste was nohotos 3-9 37-54
pair, and maintain cofencing, silt traps, vegn accordance with an
d waste. See photos 7
oil stabilization methn. More frequent sebe maintained in such
an one growing seas
with Tobin Baker
l Quality
254-S1-R4
e landfill shall be in a
gh the future cells a
er measures as appro
oted in the erosion c
ontrols to prevent offgetation filter strips, ny stormwater permi
7, 10-14
hods on both interim eeding or stabilizatioh a manner that vigo
son; therefore the sl
accordance with the a
nd borrow areas. A
opriate on steep slop
cuts and washouts. T
ff site sediment accummulching, erosion, c
it issued for the site, s
and final slopes. Inon may be required torous growth is achiev
lopes should be stab
Page
3
approved
At the
es to
There
mulation control shall be
n general, o prevent ved.
bilized to
Site Name
Reg. 22.411(o)responsible for exposure of therepaired. Comments: A
Reg. 22.429(a) of the waste madesigned to faci
Comments: Duliner. A warnDuring the ins
Date
1
Category 2 Commen
Legacy Landfi
General Operating Rmaintaining the cov
e barrier system of t
leachate leak was ob
Leachate Collection ass and disposal areilitate maintenance.
uring the inspectionning light was flashipection the facility h
1/8/2013
nts Page7/1/2012
ill
Requirements (Leachver system integrity the final cover. Area
bserved on the west
System Design And ea. The systems shal
n, it was noted that ting on the leachate had greater than 12
Sig
hate Leaks or evidenand shall promptly
as of leachate seepag
t slope of the landfil
Construction (Leachll be designed to lim
the monitor for Cellcollection 20,000 g
2 inches of head on t
gnature of Inspec
Arkansa
AFIN
Catego
nce of leachate seepay repair erosion, wge, or areas exhibitin
l. See Photos 21-23
hate collection systemit the maximum leac
l 4 was reading 89.4allon tank. Additiothe liner. See Photos
ctor
For AD
as Departm Solid Waste Com
16-00199
ory 2 Comme
age )– Cover Materiawashout, tracking, ong evidence of leacha
m )– System Requiremchate head on the bo
49 and according to onally, the monitor s 24-26, and 55
DEQ Use Only
ment of Envie Managememments Page
Permit Num
ents
al Requirements (a) or other defects thaate seepage such as s
ments - Leachate colttom liner at any po
2012 AEIR report tin that building fo
ironmental nt Division e
mber 02
Daily Cover- Coverat result in exposedstaining and discolo
llection systems shallint at any time to 30
this would indicate or the new cell was
with Tobin Baker
l Quality
254-S1-R4
r Maintenance - Thed refuse in either daioration of the cover sy
l be designed and ins0 cm (12 inches) or l
there are greater threading 38.45 and
e owner or operator ily or intermediate csystem shall also be p
stalled to facilitate deless. The system shal
han 12 inches of heathe light was flashi
Page
4
shall be cover, or promptly
ewatering ll also be
ad on the ing on it.
Site Name
Reg. 22.413 –Ccover disposed scavenging andby the Director,litter, and scave Comments: Ainches of requ Reg.22.413- Cobut not less thanwaste of final c Comment: Aexcessive amo
Date
11
Category 3 Commen
Legacy Landfill
Cover Material Requisolid waste with six
d to limit the generatir, either through indivenging without prese
At the time of the uired daily cover
over Material Requiren twelve (12) inches over within 180 days
At the time of the iount of exposed w
1/8/2013
nts Page7/1/2012
rements (Satisfactory(6) inches of earthenion of leachate. (b) Avidual requests or thr
enting a threat to hum
inspection, the facor alternative cov
ements (Satisfactory in total thickness inc
s.
inspection, there wwaste. Waste was a
Signat
A
y Daily/Alternative C material at the end olternative Cover Matrough generalized De
man health and the en
cility had not recever material from
intermediate cover) cluding the six inches
was not the 12 inchalso noted in the s
ture of Inspector
Arkansa
AFIN 16-
CategoCover)- (a) Daily Covof each operating dayterials - Alternative cepartment approval unvironment.
eived any waste fothe previous day o
(c)Interim Cover Ma of daily cover (or an
hes of required cosurface water cont
r
For AD
as Departm Solid Waste Com
-00199
ory 3 Commever- Except as providy, or at more frequencover materials of anupon demonstration t
r that day. It was of operation. See P
aterial Requirementsn approved alternate
over on the bottomtrol ditches. See p
DEQ Use Only
ment of Envie Managememments Page
Permit Num
ents ded in paragraph (d) nt intervals if necessan alternative thicknessthat the alternative m
noted that the actPhotos 27-32
: A compacted layer material), shall be ap
m 1/3 of landfill. Dphotos 33-36, 37-5
ironmental nt Division e
mber
of this section, the owary, to control diseass (other than at least
material and thicknes
tive working area
of cover soil of sufficapplied upon surfaces
Due to the lack of 54
with Tobin Baker
l Quality
0254-S1-R4
wners or operators ofe vectors, fires, odort six inches of earthenss controls disease ve
had exposed was
cient quantity to ensus that will not receive
the required cove
of all Class 1 Landfillrs, blowing litter, andn material) may be apectors, fires, odors, bl
te that did not hav
ure there is no exposee an additional applic
er, the slopes had a
Page
5
ls must d pproved lowing
ve 6
ed waste, cation of
an
5