LEA Advisory #15—June 8, 1994

Completion of Solid Waste Information System Inspection Reports for Disposal Sites and Transfer Stations

The purpose of this advisory is to provide guidance to Local Enforcement Agencies (LEA) and Board staff on the proper completion of Solid Waste Information System (SWIS) inspection forms for disposal sites and transfer stations. Since the SWIS forms provide vital information for the state-wide SWIS database, it is critical that the information be consistent, accurate and current. In addition, since the SWIS forms have recently been modified, this advisory will highlight specific changes relative to previous inspection forms and will provide general guidance on the proper completion of the amended forms. Attached are copies of the inspection report forms, CIWMB-52 for disposal sites (Excel: 97/2000, 20 KB or PDF: Adobe Acrobat, 9 KB) and CIWMB-53 for transfer stations (Excel: 97/2000, 64 KB or PDF: Adobe Acrobat, 9 KB.

General Guidelines

The following general guidelines apply to the completion of ALL SWIS forms:

• Old versions of the Disposal Site and Transfer Station SWIS forms should no longer be used for inspection reports.

• LEA inspectors should use the pre-printed, original SWIS forms (not photocopies) to report their inspection results. The white copy should be submitted to the appropriate Board Enforcement staff contact, the yellow copy to the operator, and the pink copy kept for LEA records. Please contact the appropriate Enforcement Branch staff for additional forms when needed.

In the event that SWIS forms are unavailable, photocopies of SWIS forms may be used. The LEA must ensure that the entire form is copied, that all State Minimum Standards (Standards) are included on the sheet and that the copy quality is comparable to an original. Moreover, since a completed SWIS form is public record, the original copy (filled out by  the inspector at the time of inspection) must be submitted to Board Enforcement staff.

• All information at the top of the form should be filled out. Time in, time out, and inspection time are optional, and are to be used at the discretion of the LEA. Board staff suggest, however, that this information be included to document the time of day when the inspection took place.

• All violations and areas of concern should be checked in the appropriate boxes, and an explanation of each should be given in the "Comments Section". The explanation should include the Standard number as well as whether it is a "V" (violation) or an "A" (area of concern). The purpose of this requirement is to clarify and document the nature of each  problem. Additionally it serves as a cross-check that the correct box was marked. It is essential that this cross-check be completed, to verify the accuracy of the standards marked, particularly with the elimination of the compliance "C" column.

• When a violation or an area of concern is noted, the discussion should also include, when applicable, a description of the specific actions required of the operator to correct the problem.

  The following is an example of an appropriate comment for a violation:

  • 17684 - Intermediate Cover: V - "Observed exposed waste located on the southeastern portion of Cell 3. Operator was advised to properly cover the area with 12 inches of compacted soil."

• Additional pages may be attached to the SWIS form to fully discuss all violations and areas of concern. The Board provides a three-part comments page (CIWMB-SWIS-03). If in-house inspection reports are produced for an inspection then those reports may be attached to the SWIS form in lieu of the Comments Section, with a note in the Comments Section to "See attached."

• If no violations or areas of concern are found, the inspector should write a comment to that effect, such as "satisfactory compliance" or "no violations noted."

• When violations or areas of concern noted on previous SWIS reports have been corrected, a comment to that effect should be included in the Comments Section. The following is an example of an appropriate comment for a correction implemented:
  • Corrections Implemented: 17684 - Intermediate Cover (from x/xx/94 report)

• When a recurring violation or area of concern has not been corrected, it should be so noted in the Comments Section, along with a description of the specific actions required of the operator to correct the problem. This will document the status of the operator to achieve compliance since the last inspection. Additionally, the status on any issued Notice and Order can be documented on a continuing basis. The following is an example of an appropriate comment for ongoing violations:
  • Ongoing Violation: 17705 - Gas Control - Operator submitted preliminary plans on May 1, 1994. Phase II is scheduled for completion by June 13, 1994.
  • Notice & Order # 94-01 is still in effect.  Operator is complying with current timelines.

• Use of "NA" (not applicable) should also be explained in the Comments Section to document the reason for its use. This designation should only be used when the standard does not apply, and not if the inspector did not evaluate it for some reason. Since monthly inspections are complete inspections, inspectors should evaluate all standards that are applicable to the site.

  Examples of appropriate uses of "NA" include the following:

  • Tire standards for sites that do not have any tire storage piles;
  • Closure standards for sites that are not in or approaching closure;
  • Subtitle D ("Other") standards for sites that are exempt from Subtitle D requirements;

  Examples of inappropriate uses of the "NA" designation include the following:

  • Permitting standards;
  • Any other applicable standard that the inspector did not evaluate.

• Other useful information that may be written in the Comments Section include site status (if inactive, closed, etc.) and tonnage received.

• When inspecting large volume transfer stations (LVTS), the inspector should place a diagonal line through the small volume transfer station (SVTS) Standards to indicate they are not being used. Similarly, when inspecting SVTS, a diagonal line should be made through all the LVTS Standards.

• All SWIS forms should be checked for accuracy and completeness by LEA staff before submission to the Board. Notes in the Comments Section should assist LEA staff in performing this task, since each standard marked would be discussed in the Comments Section.

• Completed SWIS forms should be submitted to Board Enforcement Branch staff within 30 days of the inspection pursuant to Public Resources Code 43218.

Overview of Changes

The new forms referred to in this advisory are the Disposal Site Inspection Report CIWMB-52 (REV 4/94) (Excel: 97/2000, 20 KB or PDF: Adobe Acrobat, 9 KB) and the Transfer Station Inspection Report CIWMB-53 (REV 4/94) (Excel: 97/2000, 64 KB or PDF: Adobe Acrobat, 9 KB). Some of the changes discussed below are in relation to the interim forms (revised in July 1993), and others are in relation to the previous Notice of Inspection forms SWIS-09 and SWIS-08.

In an effort to streamline the process of filling out SWIS forms, the new forms will no longer require checking "C" for compliance. The inspector will only use a check-mark for a standard if it is a violation, area of concern or not applicable to the site.

The "Not Evaluated" box which was added to the interim forms has also been removed from the SWIS form, since all standards should be evaluated unless they are "Not Applicable." If an inspector conducts more than one inspection per month, one of which is for the sole purpose of re-checking a particular standard, this should be noted in the Comments Section. For example, for an additional inspection of a landfill gas problem, the inspector might write, "Recheck on Gas Control 17705 only," or a similar comment indicating that this was not a regular monthly inspection.

The Comments Section has been moved to the bottom of the forms. This section should be used, along with any additional pages necessary, to explain all violations and areas of concern (see General Guidelines for further information on use of this section).

New standards have been added to the forms; some were added to the interim forms, and some to the new forms. The standards added to the Disposal Site Inspection Report form are listed below. Those added after the interim forms are identified with an asterisk (*).

The standards provided on the Transfer Station Inspection Report forms have not changed since the interim SWIS forms, although the following permit-related standards were added at that time:

Please note that the purpose of this LEA Advisory is to outline, in as much detail as possible, the specific requirements for completing a SWIS inspection form. Since the SWIS forms are the Board's major source of information about ongoing operations at solid waste facilities throughout the state, it is vital that the information in them be accurate, complete and timely. It is the intent of this advisory to establish greater procedural consistency among LEAs in terms of how the SWIS forms are completed. Please contact your Enforcement Branch staff person if you have any additional questions.

Sincerely,

Original signed by:

Deputy Director
Permitting and Enforcement Division

Attachment 1

Disposal Site Inspection Report: Excel (97/2000, 20 KB) or PDF (Adobe Acrobat, 9 KB)

Attachment 2

Transfer Station Inspection Report: Excel (97/2000, 64 KB) or PDF (Adobe Acrobat, 9 KB)

Publication #200-94-008

The intent of the advisories is to provide guidance to Local Enforcement Agencies (LEA) in performing their duties. Guidance, for this purpose, is defined as providing explanation of the Board’s regulations and statutes.

Unless included by reference in the LEA's Enforcement Program Plan (EPP), advisories are not enforceable in the same manner as regulations because they have not been adopted through the formal rulemaking process (see Government Code sections 11340.5 and 11342.6). Advisories do not take precedence over statute or regulation.

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