Maryland Department of Environment...1) There were no annual employee training records in regards to...

Maryland Department of Environment Water Management Administration

Compliance Program

1800 Washington Blvd, Baltimore, MD 21230

410-537-3510

AI ID: 13670 Inspector: Brenden Hogan

Site Name: Quarantine Road Municipal Landfill

Facility Address: 6100 Quarantine Rd, Curtis Bay, MD 21226

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 Facility Address: 6100 Quarantine Rd, Curtis Bay, MD 21226

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



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. Sediment-

laden 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.



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 Compliance 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.




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.

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 Compliance Program-Enforcement Division at 410-537-3514 or at

[email protected].

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

[email protected].

A copy of this report has been submitted to Mr. Riggin of the Quarantine Road Municipal Landfill.

http://www.mde.maryland.gov/programs/permits/watermanagementpermits/waterdischargepermitapplications/pages/permits/watermanagementpermits/water_applications/stormwater.aspx


mailto:[email protected]




NPDES Industrial Stormwater- Inspection Checklist

Inspection Item Status Comments 1. Does the facility have a discharge permit?

[Environment Article §9-323a(1-3)]

No Violations

Observed

The facility received coverage under the Permit No. 12-

SW on 8/11/14.

2. Is the discharge permit current? Has

facility applied for renewal? [Environment

Article §9-328a(1)]

No Violations

Observed

The facility received coverage under the Permit No. 12-

SW on 8/11/14.

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)]

No Violations

Observed

4. Has notification been submitted about any

new, different or increased discharges? [40

CFR Part 122 Subpart C Section 122.42.b(1-

3)]

No Violations

Observed

5. Is the number and location of discharge

points as described in the discharge permit?

[Environment Article §9-3314]

No Violations

Observed

6. Has permittee submitted correct name and

address of receiving waters? [40 CFR

122.21.j(3)]

No Violations

Observed

7. Is the permittee meeting the compliance

schedule per permit requirements? [COMAR

26.08.04.02-1.02-1A(3)]

Out of

Compliance

The compliance schedule is not being followed in

accordance to Permit conditions. See findings.

8. Has the operator or superintendent been

certified by the Board in the appropriate

classification for the facility? [COMAR

26.06.01.05A(1)]

No Violations

Observed

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)]

Out of

Compliance

See findings.

10. Are adequate records being maintained

for the analytical methods/techniques used?

[COMAR 26.08.04.03.03B(3)(d)]

Out of

Compliance

See findings.

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)]

Not

Applicable

12. Is the lab and monitoring equipment being

properly calibrated and maintained? Are they

keeping records to reflect this? [Environment

Article §9-3313]

Not

Applicable

13. Is laboratory controls and appropriate

quality assurance procedures properly

operated and maintained? [40 CFR Part 122

Subpart C Section 122.41.e]

Not

Applicable

14. Has the permittee submitted the

monitoring results on the proper Discharge

Monitoring Report form? [COMAR

26.08.04.03.03C(1)]

Not

Applicable




Inspection Item Status Comments 15. Has the permittee submitted these results

within the allotted time? [COMAR

26.08.04.03.03C(2)]

Not

Applicable

16. Are discharge monitoring reports

complete and reflect permit conditions?

[COMAR 26.08.04.03B(3)]

Out of

Compliance

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.

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]

Out of

Compliance

See findings.

18. Is sewage sludge managed correctly per

permit requirements? [COMAR

26.04.06.03.03]

Not

Applicable

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)]

Not

Applicable

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)]

No Violations

Observed

21. Have overflows occurred since the last

inspection? [COMAR 26.08.10.02A]

Not

Applicable

22. Has records of overflows been maintained

at the facility for at least five years? [COMAR

26.08.10.06A-B]

Not

Applicable

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]

Not

Applicable

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)]

Out of

Compliance

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.

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)]

Not Evaluated

26. Has the permittee notified the Department

of the name and address of the commercial

laboratory? [COMAR 26.08.04.03.03A(3)]

Not Evaluated



Brenden Hogan/9/16/15

[email protected]

410-537-3978


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]

Info 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.

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)]

Info 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


with vegetative growth.

29. Were discharge samples collected?

[Environment Article §9-261c(1)]

Not Evaluated

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)]

Out of

Compliance

See findings.

31. Are the permit conditions being met?

[Environment Article §9-326a(1)]

Out of

Compliance

See findings.

Inspector: Received by: ________________________________ __

Signature/Date

__________________________________

Print Name

Report Provided to: ________________________Raymond Riggin________________________________________ [ ] Fax ________________________________________________________________

[ ] Email [email protected]

[ ] Regular Mail ________________________________________________________________ [ ] Certified Mail ________________________________________________________________


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).



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.


Compliance Program


410-537-3510





Inspection Date: September 30, 2015 Start Date/Time: September 30, 2015, 01:15 PM

End Date /Time: September 30, 2015, 03:00 PM


Contact(s): Vivaldi Nguyen - Engineer/Supervisor

Joana Pei - Baltimore City DPW

Raymond Riggin - Supervisor

_____________________________________________________________________________________________


Site Status: Active


Recommended Action: Additional Investigation Required

Inspection Reason: Follow-up (Non-Compliance)



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



Page 2

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 7th

, 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.




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 3




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.


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 Compliance Program-Enforcement Division at 410-537-3514 or at

[email protected].






Page 4



[email protected].

A copy of this report has been submitted to Mr. Riggin of the Quarantine Road Municipal Landfill.




No Violations

Observed




No Violations

Observed




26.08.04.01.01B(4)]

No Violations

Observed




3)]

No Violations

Observed




No Violations

Observed



122.21.j(3)]

No Violations

Observed



26.08.04.02-1.02-1A(3)]

Out of

Compliance

The compliance schedule is not being followed in

accordance to Permit conditions. See findings.




26.06.01.05A(1)]

No Violations

Observed





[COMAR 26.08.04.03.03B(3)(a, b, c, e)]

Out of

Compliance

See findings.



[COMAR 26.08.04.03.03B(3)(d)]

Out of

Compliance

See findings.





reports? [COMAR 26.08.04.03.03B(1)]

Not

Applicable




Page 5


Inspection Item Status Comments 12. Is the lab and monitoring equipment being



Article §9-3313]

Not

Applicable





Not

Applicable




26.08.04.03.03C(1)]

Not

Applicable

15. Has the permittee submitted these results


26.08.04.03.03C(2)]

Not

Applicable



[COMAR 26.08.04.03B(3)]

Out of

Compliance

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.







122.41.e]

No Violations

Observed



26.04.06.03.03]

Not

Applicable




122.41.m(4)(i)(C)]

Not

Applicable





No Violations

Observed



No Violations

Observed



26.08.10.06A-B]

Not

Applicable






122.41.e]

Not

Applicable



Page 6


Inspection Item Status Comments 24. Are discharge monitoring points adequate






Out of

Compliance

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.





Not Evaluated




Info The facility plans on using KCI Labs for benchmark

monitoring.

27. Were discharges observed at the




Info 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










Info 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






Not Evaluated








122.26.c(1)(I)(A-B)]

Out of

Compliance

See findings.



Out of

Compliance

See findings.



Page 7


[email protected]

410-537-3978


Signature/Date

__________________________________

Print Name

Report Provided to: __________________________Raymond Riggin______________________________________ [ ] Fax ________________________________________________________________

[ ] Email [email protected] [ ] Regular Mail ________________________________________________________________ [ ] Certified Mail ________________________________________________________________


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.



Photo #3- Damaged inlet protection remains leaving exposed sediment to stormwater runoff. Note the

sediment –laden water in Basin A and the capped riser structure.

Photo #4- Sediment runoff across the haul road from the active cell.



Photo #5- Silt fence overtaken by sediment runoff along the haul road.

Photo #6- Damaged silt fence and exposed sediment above Basin A.


Compliance Program


410-537-3510





Inspection Date: March 16, 2016 Start Date/Time: March 16, 2016, 09:00 AM

End Date /Time: March 16, 2016, 01:00 PM


Contact(s): Douglas Carter - Acting Chief-Landfill Superintendent

Dean Bullis- MDE (LMA)

_____________________________________________________________________________________________


PAF Number: 16-2308

Site Status: Active


Recommended Action: Additional Investigation Required, Refer to Others (See Findings)

Inspection Reason: Initial Quarterly, Initial Yearly, PAF, Joint Inspection MDE



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


Page 2

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 3

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 on-

site 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 4

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


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.




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 5

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. Notes from KCI Technologies show a lack of understanding of all outfall locations on-

site. 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.


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 6

A copy of this report will be referred to Baltimore City Sediment/Erosion Control.


[email protected].

A copy of this report has been e-mailed to Mr. Carter of the Quarantine Road Municipal Landfill.




No Violations

Observed




No Violations

Observed




26.08.04.01.01B(4)]

No Violations

Observed




3)]

No Violations

Observed




No Violations

Observed



122.21.j(3)]

No Violations

Observed



26.08.04.02-1.02-1A(3)]

Out of

Compliance

No quarterly or annual facility inspections available for

review.




26.06.01.05A(1)]

Not Evaluated





[COMAR 26.08.04.03.03B(3)(a, b, c, e)]

Out of

Compliance

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.



[COMAR 26.08.04.03.03B(3)(d)]

No Violations

Observed





reports? [COMAR 26.08.04.03.03B(1)]

Not

Applicable




Page 7


Inspection Item Status Comments 12. Is the lab and monitoring equipment being



Article §9-3313]

Not

Applicable





No Violations

Observed




26.08.04.03.03C(1)]

No Violations

Observed



26.08.04.03.03C(2)]

No Violations

Observed



[COMAR 26.08.04.03B(3)]

Out of

Compliance












122.41.e]

Out of

Compliance

See findings.



26.04.06.03.03]

Not

Applicable




122.41.m(4)(i)(C)]

Not

Applicable





Out of

Compliance

See findings.



Not Evaluated



26.08.10.06A-B]

Not Evaluated






122.41.e]

Not Evaluated



Page 8


[email protected]

410-537-3978


Inspection Item Status Comments 24. Are discharge monitoring points adequate






Out of

Compliance










No Violations

Observed




No Violations

Observed





Out of

Compliance

See findings.







Out of

Compliance

See findings.



Not Evaluated








122.26.c(1)(I)(A-B)]

Out of

Compliance

See findings.



Out of

Compliance

See findings.


Signature/Date

__________________________________

Print Name

Report Provided to: _____________________Douglas Carter___________________________________________ [ ] Fax ________________________________________________________________



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.



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.



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.



Photo #7- Damaged inlet protection and sediment deposition to Basin A.

Photo #8- Evidence of overflows from Basin A.



Photo #9- Evidence of overflows from Basin A, note the gullying.

Photo #10- Outfall 4 from Basin A, some discharge present.



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.



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.



Photo #15- Turbid discharge at Outfall 1.

Photo #16- Discharge observed at Outfall 5.



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.



Photo #19- Following flow of unauthorized leachate discharge.

Photo #20- Flow of leachate leads towards monitoring well.



Photo #21- Flow of leachate flows into the ground near monitoring well.

Photo #22- Flow observed downstream of Outfall 5, no odor observed.



Photo #23- Damaged pump near leachate storage tanks on Millenium Landfill parcel.


Compliance Program


410-537-3510





Inspection Date: March 23, 2016 Start Date/Time: March 23, 2016, 11:30 AM

End Date /Time: March 23, 2016, 02:00 PM


Contact(s): Carroll Brown - Baltimore City Sediment/Erosion Control

Douglas Carter - Acting Chief-Landfill Superintendent

Dennis Peaton - Landfill Worker


_____________________________________________________________________________________________


PAF Number: 16-2308

Site Status: Active



Inspection Reason: PAF Follow-up, Violation Follow-up



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



Page 2

(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 3

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.




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 4

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.






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.




[email protected].





Page 5




No Violations

Observed




No Violations

Observed




26.08.04.01.01B(4)]

No Violations

Observed




3)]

No Violations

Observed




No Violations

Observed



122.21.j(3)]

No Violations

Observed



26.08.04.02-1.02-1A(3)]

Out of

Compliance

See findings.




26.06.01.05A(1)]

No Violations

Observed





[COMAR 26.08.04.03.03B(3)(a, b, c, e)]

Out of

Compliance

See findings.



[COMAR 26.08.04.03.03B(3)(d)]

No Violations

Observed





reports? [COMAR 26.08.04.03.03B(1)]

Not

Applicable




Article §9-3313]

Not

Applicable





Not

Applicable




26.08.04.03.03C(1)]

No Violations

Observed



Page 6


Inspection Item Status Comments 15. Has the permittee submitted these results


26.08.04.03.03C(2)]

No Violations

Observed



[COMAR 26.08.04.03B(3)]

Out of

Compliance

See findings.







122.41.e]

Out of

Compliance

See findings.



26.04.06.03.03]

Not

Applicable




122.41.m(4)(i)(C)]

Not

Applicable





Out of

Compliance

Leachate discharge on-site in on-going. See report

findings 3-16-16.



Not Evaluated



26.08.10.06A-B]

Not Evaluated






122.41.e]

Not Evaluated







Out of

Compliance

See findings.





No Violations

Observed




No Violations

Observed





Out of

Compliance

See findings.



Page 7


[email protected]

410-537-3978


Inspection Item Status Comments 28. Does the discharges or receiving waters






Out of

Compliance

See findings.



Not Evaluated








122.26.c(1)(I)(A-B)]

Out of

Compliance

See findings.



Out of

Compliance

See findings.

Inspector : Received by: ________________________________ __

Signature/Date

__________________________________

Print Name

Report Provided to: _______________________Douglas Carter_________________________________________ [ ] Fax ________________________________________________________________





Photo #1- Sediment deposition still present in Basin 4.

Photo #2- Vegetation still present on dewatering device of Basin 4.



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.



Photo #5- The unaddressed ash runoff from the top of the active cell 6.

Photo #6- The repaired silt fence along the haul road.



Photo #7- Active leachate discharge on the Millenium Landfill parcel.

Photo #8- Active leachate discharge on the Millenium Landfill parcel.



Photo #9- Leachate discharge path from the source to the monitoring well.

Photo #10- Where the leachate flowed towards the monitoring well.



Photo #11- Evidence of leachate spilled from pumping and transfer operations to the truck.


Compliance Program


410-537-3510





Inspection Date: April 14, 2016 Start Date/Time: April 14, 2016, 12:30 PM

End Date /Time: April 14, 2016, 03:00 PM


Contact(s): Douglas Carter - Landfill Superintendent

Vivaldi Nguyen - Engineer


_____________________________________________________________________________________________


Site Status: Active



Inspection Reason: Initial Quarterly, Follow-up (Non-Compliance)



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


Page 2

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 3

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 post-

inspection once provided.



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.



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 4

*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.*








Findings from today’s inspection were discussed with the Department’s Land Management

Administration.


[email protected].





No Violations

Observed




No Violations

Observed




26.08.04.01.01B(4)]

No Violations

Observed




3)]

No Violations

Observed




No Violations

Observed



122.21.j(3)]

No Violations

Observed



26.08.04.02-1.02-1A(3)]

No Violations

Observed

The facility has begun to implement routine inspections

per Permit conditions. New monitoring results are not yet

available for review.




Page 5


Inspection Item Status Comments 8. Has the operator or superintendent been



26.06.01.05A(1)]

No Violations

Observed





[COMAR 26.08.04.03.03B(3)(a, b, c, e)]

Not Evaluated Visual and benchmark monitoring records are not

available for review at this time.



[COMAR 26.08.04.03.03B(3)(d)]

Not Evaluated





reports? [COMAR 26.08.04.03.03B(1)]

Not

Applicable




Article §9-3313]

Not

Applicable





Not

Applicable




26.08.04.03.03C(1)]

Not Evaluated



26.08.04.03.03C(2)]

Not Evaluated



[COMAR 26.08.04.03B(3)]

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.







122.41.e]

No Violations

Observed



26.04.06.03.03]

Not

Applicable




122.41.m(4)(i)(C)]

Not

Applicable



Page 6


Inspection Item Status Comments 20. Any non-complying discharges




No Violations

Observed



No Violations

Observed



26.08.10.06A-B]

Not

Applicable






122.41.e]

Not

Applicable







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.





Not Evaluated




No Violations

Observed





No Violations

Observed







Out of

Compliance

See findings.



Not Evaluated








122.26.c(1)(I)(A-B)]

Out of

Compliance

See findings.



Out of

Compliance

See findings.



Page 7


[email protected]

410-537-3978


Signature/Date

__________________________________

Print Name

Report Provided to: Douglas Carter

[ ] Fax ________________________________________________________________





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.



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.



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.



Photo #7- Ash removed from the face of active cell 6.

Photo #8- Damaged inlet channel remains to Basin A. Basin A remains capped.



Photo #9- Basin 4 with sediment accumulation- dewatering device remains vegetated.

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