Document ID 072287

02-04-11

June 25, 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 June 18, 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 072287

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 # 072287

Date 6/18/2013 Entry Time Exit Time 12:00

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 411(a) Operations in accordance with permit documents

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

Category 2 (continued)

Regulation Item Description Comments

R 427 Surface Water Controls See Category 2 comments page

411(h)(1) Contouring prevents surface water flowing into or through waste

418(a)(b) Run-on/off control system present and adequate

R 411(h)(2) Surface water control prevents off-site sediment accumulation See Category 2 comments page

R 411(i);427(f) Adequate maintenance of intermediate/final cover vegetation See Category 2 comments page

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

413(a)(b) Satisfactory daily/alternative cover

X 413(c) Satisfactory intermediate cover See Category 3 comments page

416(b),411(f)(4) Open burning prohibited

419 Cause discharge/leachate discharge leaving landfill

X 411(f)(3),419(a)(4) Depositing waste in standing water prohibited See Category 3 comments page

411(o) Erosion or other cover defects resulting in exposed refuse

309(c) Overfill/Off lined area

Regulation 22 - Records 421(a)(8), 1203(k) Date of last groundwater monitoring report 1-24-2013

423(b) Date of last engineering report 3-30-2013 428 Liner construction in progress Yes/No NO Notice of liner construction Yes/No Yes Third party CQA on-site during construction Yes/No Yes

412(a) Date of last random inspection for unauthorized waste 6/10/2013 Total # for month 15 415, 421(e) Date of last quarterly methane monitoring 3/2/2013 Detection level Above 415(a) Explosive gas records current? Yes/No yes

421(g),412(a)(2),701 Date of last special waste received 6/17/2013 Disposal location Cell 4, Unit 6 421(d) Previous quarter waste received Tons Class 1-17984.53Ton Class 4-7,819.54Ton 427(c) Surface water DMR records current? Yes/No Yes

Fayetteville Shale Related Yes/No No Fayetteville Shale Violation Yes/No No Violation

Operator Name & Number

Ronnie Lumley 000606

Signature of Inspector

Exit Interview Conducted with Robert Hendrix Method On site Date 6/18/2013 Time 12:00

Class 1Form 7/1/2012 For ADEQ Use Only

Site Name Legacy Landfill AFIN 16-00923 Permit Number 0254-S1-R4

Category 2 Comments Reg. 22.427-Surface Water Controls (Surface Water Controls) (d) Erosion Control- The design shall also include berms, swales, benches, downchutes and other measures as appropriate on steep slopes to minimize erosion. In areas where flow quantity and velocity warrant, rip rap, gabions, revetments, or other protection shall be provided. Comments: During the inspection, there were no BMP’s maintained to minimize erosion on the slopes throughout the landfill. This erosion and BMP’s violation has been noted since the 1st quarter 2012. Additionally, waste was noted in the erosion cuts and in storm water ditches. See Photo 3,4,7,8,29,30,35,36,43,44,47 Reg.22.411 General Operating Requirements ( Surface water control prevents off-site sediment accumulation) (h) (2) Install, construct, repair, and maintain controls to prevent off site sediment accumulation at all landfill, soil stockpile, and borrow site areas. Temporary and permanent seeding, grading, diking, terracing, diversion ditches, silt fencing, silt traps, vegetation filter strips, mulching, erosion, control blankets, and matting, gravel filter berms, check dams, riprap, sediment ponds, and other best management practices for the site shall be in accordance with any stormwater permit issued for the site, shall be described in the operating narrative, and shall be included in the permit plans as appropriate. Comments: During the inspection, the surface water control ditches had a large amount of sediment accumulated and waste. Additionally noted on the storm water; was that the sedimentation pond had a break/breech in it allowing the water to flow into the future cells and the borrow areas. See Photo 9,10,13,14,15,16,17,18,21,22,23,24,27,28,29,30,31,32,33,34 Reg. 22.427 – Surface Water Control (Final and Interim Slope Stabilization) (f) - The operating narrative shall describe seeding and soil stabilization methods on both interim and final slopes. In general, exposed slopes shall be seeded or stabilized if it is anticipated that these slopes will not be disturbed for more than one growing season. More frequent seeding or stabilization may be required to prevent erosion of the cover system. The narrative shall also describe vegetative maintenance procedures and shall provide that vegetation shall be maintained in such a manner that vigorous growth is achieved. Comments: At the time of inspection, the slopes lacked vegetative cover and have not received waste for more than one growing season; therefore the slopes should be stabilized to prevent erosion. This lack of vegetation violation has been noted since the 1st quarter 2012. See Photo 3,4,5,6,27,28,29,30,35,36,37,38,41,42,43,44

Date

6/18/2013


Page

3

Category 2 Comments Page7/1/2012 For ADEQ Use Only


Solid Waste Management Division Comments Page

Site Name Legacy Landfill AFIN 16-00923 Permit Number 0254-S1-R4

Category 3 Comments Reg.22.413- Cover Material Requirements (Satisfactory intermediate cover) (c)Interim Cover Material Requirements: A compacted layer of cover soil of sufficient quantity to ensure there is no exposed waste, but not less than twelve (12) inches in total thickness including the six inches of daily cover (or an approved alternate material), shall be applied upon surfaces that will not receive an additional application of waste of final cover within 180 days. Comment: During the inspection, the slopes had an excessive amount of exposed waste. Waste was also noted in the surface water control ditches. There was tracked waste on the roads and around the shop. There was insufficient cover throughout the landfill allowing large amounts of waste to be exposed. There were areas of washout and erosion cuts that had exposed waste. See Photo 1,2,3,4,5,6,7,8,11,12,13,14,15,16,17,18,19,20,21,22,23,24,25,26,27,28,29,30,31,32,33,34,35,36,39,40,41,42,43,44,45,46 Reg.22.419 (a) General Requirements –( Depositing waste in standing water prohibited) As provided in 40 CFR 258.27 all Class I landfills shall not (4) Deposit waste in standing water; and (5) Allow the discharge of leachate from the landfill unit unless the discharge is permitted under NPDES system. Comment: During the inspection, it was noted that waste was in contact with water. The current operating face was adjacent to water and some waste had be deposited in the water. Additionally, waste was noted in the surface water control ditches. Any of the water in contact with the waste should be treated as leachate. 29,30,31,32,33,34

Date

6/18/2013


Page

5

Category 3 Comments Page7/1/2012 For ADEQ Use Only


Solid Waste Management Division Comments Page

Permit# 0254-S1-R4 Photo 1 & 2

Permit# 0254-S1-R4 Photo5 & 6

Permit# 0254-S1-R4 Photo 47

Document ID 072287

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