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 angela@ccswda.com 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

Q Use Only

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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

Tim

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urrent? Yes/No

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Yes

Yes

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.

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For AD

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16-00199

ory 2 Commets) Conformance with

he approved plans. an on-site ditch. See

hall also include bermts, or other protection

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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

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All operations at the

being routed throug

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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

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AFIN

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nce of leachate seepay repair erosion, wge, or areas exhibitin

l. See Photos 21-23

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l 4 was reading 89.4allon tank. Additiothe liner. See Photos

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16-00199

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m )– System Requiremchate head on the bo

49 and according to onally, the monitor s 24-26, and 55

DEQ Use Only

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Permit Num

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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

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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

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ed waste, cation of

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5

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