LEA Advisory #54—October 26, 1998

1998 Inspection Guide for Solid Waste Landfills--Part 6

Roads

Roads within the permitted facility boundary shall be designed to minimize the generation of dust and the tracking of material onto adjacent public roads. Such roads shall be kept in safe condition and maintained such that vehicle access and unloading can be conducted during inclement weather.

Internal roads should be built so that vehicles using the road do not generate excessive dust that would obscure visibility. In addition, vehicles should not "bottom out" (scrape the vehicle undercarriage) in ruts or become stuck when using the road. This standard only applies to that portion of the internal roads within the permitted facility boundary. If vehicles bottom out or become stuck in the road that is a violation of this standard. The signs should direct the public to the active disposal area or other appropriate unloading area.

Sanitation

Sanitary facilities, consisting of an adequate number of toilets and handwashing facilities shall be available to personnel at the site or in the immediate vicinity of the site as approved by the EA.

For purposes of uniformity adequate sanitary facilities consist of a sanitary toilet and handwashing facility with soap. The inspector must use his/her discretion, based on site-specific conditions, to decide what is to be considered the "immediate vicinity."

Safe and adequate drinking water for the site personnel shall be available.

The operator should provide the water supply, personnel should not be required to bring their own water. Employees may forget to bring water and/or weather or unexpected conditions may require the availability of an additional supply. A city water line, bottled water, clean water tanks certified structurally sound, or wells tested potable by the local health agency are acceptable. Since this regulation was written it has been determined that part of this requirement is within the jurisdiction of Cal-OSHA. Therefore, if there is a problem with safe and adequate drinking water, a referral should be made to Cal-OSHA unless the problem could also impact public health and safety as well.

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Communications

Each site shall have communication facilities available to site personnel to allow quick response to emergencies.

The use of functional two-way radios or cellular phones meets the communication requirement of this section. The inspector should note the facility telephone or radio number in the inspection report.

Lighting

Where operations are conducted during hours of darkness, the site and/or equipment shall be equipped with adequate lighting as approved by the EA to ensure safety and to monitor the effectiveness of operations.

Lights on or from vehicles, without other sources of light at the working face, are not adequate to meet the requirements of this standard. Portable light standards, powered by their own generators, are the appropriate equipment necessary to adequately illuminate nighttime solid waste disposal operations. Since this section was written it has been determined that part of this requirement is within the jurisdiction of Cal-OSHA. Therefore, if problems are observed where the only concern is personnel health and safety a referral should be made to Cal-OSHA. Where operations cannot be properly conducted the EA has jurisdiction and may cite an area of concern or violation in the inspection report.

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Personnel

Operating and maintenance personnel shall wear and use appropriate safety equipment as required by the EA.

EAs should review the operator's injury and illness prevention program (IIPP), which is required by Title 8 of the CCR (8 CCR). Although EAs and CIWMB staff are not authorized to enforce these requirements, the information regarding appropriate health and safety gear, as approved by Cal-OSHA, should be contained in this document. Section 20590 indicates that the EA has the authority to require additional personal protective gear as the EA deems necessary. However, since the section was written it has been determined that this requirement is within the jurisdiction of Cal-OSHA. A violation may no longer be given here because of overlap with Cal-OSHA. If the inspector believes that appropriate safety equipment is not in use by site personnel, or if the EA feels that the IIPP is insufficient to protect facility staff, this should be noted and a referral should be made to Cal-OSHA and a letter drafted to the operator stating the reason for the recommendation. If a disposal site has salvaging or volume recovery operations the inspector should look closely for personnel safety concerns.

Note: 8 CCR, enforced by Cal-OSHA, contains personnel health and safety requirements. If the inspector is aware of a possible violation of 8 CCR regulations, Cal-OSHA should be informed.

Personnel assigned to operate the site shall be adequately trained in subjects pertinent to the site operation and maintenance, including the requirements of this chapter, hazardous materials recognition and screening, and heavy equipment operations, with emphasis on safety, health, environmental controls and emergency procedures. A record of such training shall be placed in the operating record.

The inspector should ask site supervisors and personnel about the facility's training programs for operations, maintenance and safety. If answers are vague and/or no training program can be documented this is an indication that training is adequate. Essential disposal site training includes personnel safety, hazardous materials recognition and screening, and heavy equipment operations in waste. Since this section was written, it has been determined that part of this requirement is within the jurisdiction of Cal-OSHA. Thus, where the only training not provided is personnel safety a referral should be made to Cal-OSHA.

In accordance with §20870–Hazardous Wastes, site personnel shall be trained to recognize regulated hazardous wastes and PCB wastes. A record of this training must be placed in the operating record.

Note: 8 CCR §64107.7, enforced by Cal-OSHA, sets training requirements for worker safety. The IIPP may be referenced for site specific training requirements.

The site operator shall provide adequate supervision of a sufficient number of qualified personnel to ensure proper operation of the site in compliance with all applicable laws, regulations, permit conditions and other requirements. The operator shall notify the enforcement agency and local health agency in writing of the names, addresses, and telephone number of the operator or responsible party. A copy of the written notification shall be placed in the operating record.

During the inspection the inspector should make a list of site personnel, including the names and titles of key site officials and numbers and types of personnel by function. After watching the day's operations the inspector should consider the daily tonnage, types and quantities of equipment, and overall site operations to determine if the number of personnel is adequate to properly handle all site operations in a safe and environmentally responsible manner. Failure to comply with SMS relating to cover, litter control, supervision, recordkeeping, etc. may be indicative of noncompliance with this section.

The existence of a number of violations of other SMS can be indicative of poor supervision and may be cause for citing a violation of this section. If a site has a chronic problem with several operational minimum standards that are related to a lack of proper resource utilization (staffing and/or equipment) a supervision violation should be considered.

The site supervisor should be present at the facility for at least a portion of the working day. Responsible supervision includes ensuring that all personnel use appropriate health and safety gear at all times.

Evidence must be substantiated that the EA and local health agency have verification of the name, address, and telephone number of the operator/owner.

Any disposal site open to the public shall have an attendant present during public operating hours or the site shall be inspected by the operator on a regularly scheduled basis, as determined by the EA.

If the site does not have an attendant and the EA determines a schedule for inspection by the operator the site should be visually monitored by landfill personnel for problems of health, fire, or safety in accordance with this schedule. CIWMB staff recommends that a written schedule be established by the EA and a copy forwarded to the operator.

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Confined Unloading

Unloading of solid wastes shall be confined to as small an area as possible to accommodate the number of vehicles using the area without resulting in traffic, personnel, or public safety hazards. Waste materials shall normally be deposited at the toe of the fill, or as otherwise approved by the EA.

The unloading area at a disposal site should be just large enough to handle the number of vehicles using it without causing traffic safety problems, personnel or public safety hazards, or waiting or stacking up of vehicles. A smaller working face will minimize birds, vectors, dust, odor, litter, and infiltration of moisture during storm events; also, the amount of daily cover needed will be reduced. Many landfills have separate unloading areas for commercial and public garbage. The spotter should direct vehicles to the proper area.

Spreading and Compacting

Solid waste shall be spread and compacted in layers with repeated passages of the landfill equipment to minimize voids within the cell and produce maximum compaction. The loose layer shall not exceed a depth of approximately two feet before compaction. Spreading and compacting shall be accomplished as rapidly as practicable, unless approved otherwise by the EA.

Adequate spreading and compaction eliminates voids that can allow for the harborage of rodents, minimize the risk of fire, minimize subsidence (which can lead to ponding and other problems), and save landfill space. Compaction consists of repeated passes (3 to 5) over the waste with heavy equipment. Excessive "listing" and tipping of equipment during spreading of waste may indicate that waste is exceeding 2 feet prior to compaction—a violation of this standard. When a large number of waste loads are allowed to accumulate before spreading and compacting the potential for a violation exists. It becomes increasingly difficult to spread the waste into layers less than two feet in thickness.

The slope of the working face should not be so steep that the equipment in use becomes unstable or unable to exert the proper compaction or that materials in the working face are at or near their angle of repose. The angle of repose is the maximum slope or angle at which a material such as soil or loose rock remains stable. When exceeded, mass movement by slipping as well as by water erosion may be expected. Generally, slopes greater than 1 ¾:1 (~30 degrees as determined by a clinometer) are too steep. The slope will affect the degree of compaction, with the greatest compaction being achieved with the least slope.

Covered surfaces of the disposal area shall be graded to promote lateral runoff of precipitation and to prevent ponding. Grades shall be established of sufficient slopes to account for future settlement of the fill surface. Other effective maintenance methods may be allowed by the EA.

A violation should be considered if, during the inspection, there is evidence of extensive ponding or poor lateral runoff (e.g., a smooth silt layer) on fill surfaces due to subsidence or improper grading. A violation may be cited if, during dry weather, there are extensive depressions that could allow ponding should precipitation occur, or grading of fill surfaces does not promote lateral runoff. The operator should be encouraged to conduct periodic surveys to determine if the grades of fill surfaces are adequate.

Note: Under §21090 the RWQCB requires that closed landfills be provided with slopes of at least three percent and should be informed if grading problems are identified during an inspection.

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