LEA Advisory #54—October 26, 1998

1998 Inspection Guide for Solid Waste Landfills—Part 3

Preinspection Procedures

During the preinspection workup the inspector should read and become familiar with all sections of the most current valid solid waste facilities permit (SWFP), and either the Report of Disposal Site Information (RDSI) or the newly required Joint Technical Document (JTD), whichever type of document is referenced in the SWFP and governs operations of the facility. If the facility is operating under a JTD the inspector should focus on those sections identified in the JTD index as satisfying the requirements within the authority of the LEA/CIWMB. For the remainder of this guidance document when a JTD is referred to it means a JTD or RDSI, whichever document is governing that facility at the time. Before conducting the inspection the information in these documents should be scrutinized for consistency and then later be evaluated on site analyzing actual facility conditions and operations. The inspector should then determine if the facility is in violation of any of the applicable permit related statutes and/or regulations (PRC §§ 44002, 44004, 44014(b), and 27 CCR §§ 21630, 21640 and 21675).

LEA inspections should be coordinated in advance with other appropriate agencies when issues or potential problems are involved that may require their input. The appropriate agency should always be contacted concerning issues for which they have statutory or regulatory authority. In some cases, it may be appropriate to contact several agencies (e.g., RWQCB or the Air Pollution Control District) prior to the inspection.

Inspection Procedures

Inspections performed pursuant to PRC §43218 and 27 CCR should include, at a minimum, a review of all standards included in 27 CCR, Division 2, Subdivision 1, CIWMB’s "Consolidated Regulations for Treatment, Storage, Processing or Disposal of Solid Waste." The inspection should also include a review of the facility's permit conditions. Noncompliance with any applicable permit condition should be noted in the inspection report. The review should include any local regulatory requirements for which the LEA has enforcement authority, in addition to those of the state.

The time allotted for a field inspection depends upon the size and complexity of the facility, as well as the frequency of inspection. The guidance presented in this document is intended to cover a thorough inspection of any MSWLF. All inspection-related procedures are listed so that the EA may have access to such information. It is understood that a monthly inspection of a SWF by the EA may not require consideration of each and every item presented here. However, the EA is responsible for verifying that the facility is either in compliance or in violation of all applicable SMS each month. Inspections should always be unannounced to the site operator, unless prevented by extraordinary circumstances.

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Arriving at the Facility

In order to detect unpermitted operations and verify facility operating hours, application of daily cover, and security precautions the inspector should arrive at the facility before it opens in the morning. This is not possible at all facilities, i.e., those with continuous operations. In those cases, the inspector should evaluate the cover standard at the time cover is required to be deposited in accordance with the JTD, RDSI or SWFP.

Gaining Access

When entering a facility for the first time the inspector should drive first to the gatehouse via the same entry point used by the public and/or contract waste haulers. At the gatehouse the inspector should state the following: name, employer, reason for site visit, and that photos may be taken as documentation. The employee at the gatehouse will either tell the inspector to go on with the inspection or direct the inspector to speak with an official at the facility.

If no employee is present at the gatehouse, or there is no gatehouse or scalehouse, the inspector should attempt to find an employee at the site by going to the office area, maintenance area, or the working face. Upon finding an employee the inspector should follow the introduction above.

Meeting Site Personnel

Early in the day the inspector should determine the best time to interview appropriate site personnel and to inspect facility records. This will allow the inspector to arrange for a supervisor or facility manager to be present to answer questions and to find or provide access to records. It will also allow for arrangements to be made to get any necessary keys to locked gas wells, arrange for observation of gas monitoring, etc. The inspector should also notify the operator that an exit interview will be conducted at the conclusion of the inspection. If the operator is unable to attend or send a representative the inspector should make additional arrangements with the operator regarding the exit interview or conduct the interview by telephone.

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Denial of Access

If access is denied in any way the inspector should politely determine if the individual denying access is the appropriate official to make such a decision. The inspector should ask the reason for denial of access and verify that the purpose and authority to conduct the inspection under the PRC are understood. If access is still denied the inspector should abide by the operator's wishes, document the name of the person denying access, and then call his/her supervisor. The supervisor, working with the appropriate county, state, or Cal/EPA legal staff, should pursue the steps necessary to gain access using an inspection warrant.

In addition to outright denial of entry, access denial may include preventing the inspector from bringing in necessary equipment (camera), preventing access to documents, or denying entry if the inspector refuses to sign a waiver or other legal document(s) restricting the owner/operator's liabilities or obligations.

The reception of the inspector and the helpfulness of SWF officials will vary from site to site. Most inspections can be accomplished without adversarial confrontations. However, inspectors may be threatened by facility representatives during an inspection. If threatened with violence the inspector should immediately stop the inspection, leave the site or area where the threat exists, and contact his/her supervisor as soon as possible. The name of the person who has threatened violence and nature of the threat should be noted in the inspection report.

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Health and Safety Considerations

CIWMB staff recommends that each jurisdiction develop a health and safety plan for conducting inspections of solid waste facilities. The plan should include equipment requirements for field staff. For reference, the CIWMB's Field Health and Safety Plan requires CIWMB inspectors to wear overalls, hard hat, safety vest, safety glasses, and safety boots during an inspection. Ear protection and a dust mask should also be immediately available in hand or in the inspector’s vehicle (see Appendix A for recommended health and safety equipment). An effective field health and safety program is directly related to the dedication with which it is implemented by the inspectors.

The inspector should avoid areas of potential danger within, or adjacent to, the facility such as unmarked internal roads that might be haul roads for heavy equipment, steep slopes, and uneven ground that may also be unstable. In addition, the inspector should be watching out for unfriendly fauna and flora including possible hazards such as bees, wasps, spiders, snakes, bears, coyotes, feral animals, berry patches, and poison oak.

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Landfill Gas

The CIWMB's Field Health and Safety Plan requires CIWMB inspectors to continuously monitor for landfill gas (LFG) within the boundaries of the facility while onsite using a combustible gas indicator (CGI). The inspector should avoid exposure to landfill decomposition gas at or near gas collection and venting systems. The inspector should always stay upwind of potential sources of LFG. Enclosed areas or confined spaces including buildings, structures, or any low areas where gas may collect, such as sumps, drains, tunnels, and structures housing gas collection systems, should not be entered without first performing an air safety survey with a CGI.

Maintenance and equipment areas should be checked for LFG hazards within on-site structures and for general safety problems. On-site structures and existing gas monitoring probes or probe holes installed by the inspector should be monitored during the warmest part of the day (usually 2:00 - 3:00 p.m.). This is because cooler temperatures (higher atmospheric pressures) tend to suppress LFG migration. For comprehensive procedures regarding LFG monitoring see LEA Advisory #44.

Landfill Areas

A disposal site has three major areas covered by SMS. These areas include the working face, site perimeter, and access road/gatehouse/office area. Other areas to be checked at a disposal site include:

• Recycling and/or salvaging areas (for illegal waste, fire or safety hazards, and excessive buildup of salvageable materials).
• The remainder of the landfill surface (for proper cover, grading, and unpermitted activities).
• Special waste areas (for proper handling procedures, fencing, and signing).

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Working Face

Immediately after gaining access the inspector should drive to the working or active face of the landfill. This will usually allow the inspector to witness the condition of the working face from the previous day's operation and to learn if unpermitted nighttime operations are taking place. If the site is still in darkness inspectors should remain in their vehicle and travel only on the maintained access road to the working face.

At the working face at least a dozen SMS can be evaluated, fully or partially, using the SWIS inspection form for disposal sites. These minimum standards include the following 27 CCR Sections:

20580—Lighting
20590—Personnel Health and Safety
20610—Training
20615—Supervision
20630—Confined Unloading
20640—Spreading and Compacting
20680—Daily Cover
20710—Scavenging, Salvage and Storage
20740—Equipment
20780—Burning Wastes
20810—Vector and Bird Control
20870—Hazardous Waste

The working face, especially at a large landfill, should be observed several times throughout the day of the inspection, and at least one of the observation periods should be for 20-30 minutes. The inspector should use his/her safely parked vehicle or a safe overlook as an observation location. In this way an inspector can observe, among other things, equipment operations at the working face, traffic flow, waste screening, scavenging, safety procedures, and adequacy of facility equipment.

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Site Perimeter

The inspector should walk and/or drive the entire perimeter of the disposal site when possible. Conditions at the perimeter can vary daily and violations may also occur in less visible areas. While at the facility perimeter the inspector can partially or fully evaluate the following 27 CCR minimum standards:

20530—Site Security
20760—Nuisance Control
20790—Leachate Control
20820—Drainage and Erosion Control
20830—Litter Control
20840—Noise Control
20919—Gas Control (monitor existing probes)

When possible, the inspector should check the lowest area of the perimeter where leachate is most likely to leave the site and where most washout areas occur. Even in the dry season, a prior ponding situation can be detected by looking for dried and cracked silted areas.

The inspector should also go to the highest area of a disposal site to get an overall view of the layout of the operation. This is also a good time and place to decide on how to prioritize the inspection relative to the standards that are going to be evaluated. This is a good place to draw a facility map or to note changes on a suitable existing facility map.

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Access Road/Gatehouse/Office Area

At the access road/gatehouse/office area the inspector should evaluate traffic flow, signs, sanitary facilities, records, communication facilities, and drinking and washing facilities. This is also the area where the operator should conduct general or visual load screening for hazardous materials.

Exit Interview

At the beginning of the inspection the inspector should notify the operator that an exit interview will be conducted at the conclusion of the inspection. The exit interview is a summary of the inspection results, which allows the inspector to communicate inspection findings to the operator. If the operator is unable to attend or send a representative the inspector should contact the operator by telephone.

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