LEA Advisory #54—October 26, 1998

1998 Inspection Guide for Solid Waste Landfills—Part 8

Scavenging/Salvaging/Processing

(a) Scavenging is prohibited at any disposal site.

(b) Salvaging as approved by the EA shall be conducted in a planned and controlled manner and shall not interfere with other aspects of site operations, including the expeditious entry and egress of vehicles at the site.

(c) Salvaged materials generated on-site or imported shall be placed for storage in a specified clearly identifiable area segregated from the working face. Salvaged materials shall be arranged so as to minimize risk of fire or other hazard or nuisance, and be limited to a volume as approved by the EA.

Salvaging is distinguished from scavenging in that salvaging is a permitted activity and carried out by facility staff. Salvaging operations should be described in the JTD. The storage of salvaged materials should not interfere with other operations and the height and volume of stored salvage, especially piles of salvaged metals, should not be conducive to possible safety, health, or fire problems.

The inspector should request to see documentation of removal frequency for each type of material being stored, e.g., tires, white goods. Removal frequencies may vary but should be reasonable and account for the amount and type of material being stored as well as proximity to markets for that material or commodity.

Note: California Penal Code, §402(b) (Appendix D) requires that doors be removed or latches disabled from discarded white goods to prevent children from becoming entrapped.

Drugs, cosmetics, foods, beverages, hazardous chemicals, poisons, medical wastes, syringes, needles, pesticides and other similar materials capable of impairing public health shall not be salvaged unless approved by the EA and the local health agency.

It is recommended that any approval by the EA to salvage items described in the section be placed in the operating record.

Volume reduction such as incineration, baling, shredding, composting, pyrolysis, and materials and energy recovery operations as approved by the EA shall be confined to specified, clearly identifiable areas of the site. If volume reduction is conducted, operations shall be done in a controlled manner as an integral part of the operation and not interfere with the proper construction and maintenance of the site or create health, safety, or environmental problems.

The inspector should look for the creation of excessive dust, litter, or incidental waste during volume reduction activities. Repeated or excessive handling of materials during volume reduction or resource recovery on site may significantly increase the impact that segregating these by-products have on the rest of the operation, especially the creation of excessive dust and litter.

Equipment

27 CCR §20740 Equipment

Equipment shall be adequate in type, capacity and number, and sufficiently maintained to permit the site operation to meet requirements of these standards.

Throughout the inspection the inspector should visually evaluate the overall maintenance level of site equipment, and the quality of site maintenance facilities. The inspector should also evaluate the size and adequacy of the equipment to carry out operations, including the types and quantities of major landfill equipment such as dozers, scrapers, compactors, and water trucks. Equipment breakdowns happen often at landfills. However, major or widespread equipment breakdowns prior to or during the inspection may be indicative of an overall maintenance problem. Chronic or frequent violations of sections §20680 (Cover), §20640 (Spreading and Compacting), §20700 (Intermediate Cover), and §20650 (Grading of Fill Surfaces) may suggest equipment problems.

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Maintenance

The operator shall implement a preventative maintenance program to monitor and promptly repair or correct deteriorated or defective conditions with respect to requirements of the CIWMB standards, and conditions established by the EA. All other aspects of the site shall be kept in a state of reasonable repair.

Evaluation of a facility under this section involves observation of the basic maintenance level of environmental control systems (e.g., landfill gas control system), cover, signs, roads, grading, drainage and erosion controls, and other maintenance conditions. When an inspector finds three or more violations of the above SMS it is likely that the requirements of this section are not being met. The inspector should note an area of concern or a violation.

Nuisance

Each disposal site shall be operated and maintained so as not to create a public nuisance.

Section 20164 defines "nuisance" as "anything that is injurious to human health or is indecent or offensive to the senses and interferes with the comfortable enjoyment of life or property, and affects at the same time an entire community, neighborhood, household or any considerable number of persons although the extent of annoyance or damage inflicted upon an individual may be unequal and that occurs as a result of the storage, removal, transport, processing or disposal of solid waste."

Violations of other standards can exist without necessarily being or becoming a nuisance. If the EA feels that a documented violation also constitutes a nuisance, then a violation of this section is warranted, which may give the EA more enforcement authority in resolving the outstanding problem.

This standard may be used to address a noise nuisance since §20840–Noise Control only addresses health hazards from noise. In addition, a glare nuisance may be addressed under this standard. If a nuisance is related to water quality the appropriate RWQCB should be informed. An example would be receipt of a complaint of odor or color changes observed in water from domestic wells that may have occurred as a result of landfill operations.

Odors are excessive at a disposal site if they are detected at objectionable levels by the inspector at a property boundary bordered by residences or other sensitive receptors. The detection of off-site odors may result from landfill gases that typically consist of potentially hazardous and toxic components. Use of odor masking agents does not alleviate any hazard from landfill gas. Their use may actually interfere with the detection and monitoring of landfill gases making it difficult to evaluate their potentially harmful effects and may delay required corrective action. Chronic and/or excessive odors should be brought to the attention of the appropriate air quality agency (AQMD, APCD, or ARB).

An area of concern may be noted if the site has had numerous odor violations issued by the APCD or AQMD and/or a recent history of citizen complaints, but the inspector does not observe a violation of this standard during the inspection.

Feeding of solid waste to animals that will be used for human consumption is expressly prohibited on disposal sites. Grazing of livestock away from operating areas is permitted.

Further guidance is not necessary.

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(a) Open burning of solid waste, except for the infrequent burning of agricultural wastes, silvicultural wastes, landclearing debris, diseased trees, or debris from emergency clean-up operations, is prohibited at all solid waste landfills.

(b) If burning wastes are received, they shall be deposited in a safe area and extinguished. If burning wastes have been placed in an active face, they shall be immediately excavated, spread and extinguished.

Open burning is defined under §20164. Burning of exempted waste must be done in an area dedicated for that purpose away from the working/tipping area to avoid the accidental burning of other solid waste. All approvals from involved authorities should be obtained prior to the commencement of burning. Burning of solid waste in an incinerator that is not equipped with adequate air pollution control equipment is also prohibited. Routine burning of solid waste is prohibited at all MSWLF units.

Disposal sites must comply with all fire control requirements of local fire control authorities or with other fire line or firebreak requirements in the SWFP. If it is determined that requirements are not being met the local fire authority should be informed. The inspector should note a violation if there is intentional burning at the site or a hot load (smoldering ashes) is received and the above procedures are not followed. The local fire authority should be informed. Accidental fires are not a violation of this standard.

The RWQCB should be informed, if they do not already know, of discharges resulting from fire or fire extinguishing. Possibly hazardous discharges resulting from tire fires should be brought to the attention of the local Hazardous Materials Team and the DTSC.

Note: PRC §44151 requires that any solid waste facility, located outside of any city, be maintained in compliance with the flammable clearance provisions of Chapter 5 (commencing with Section 4371) of Part 2 of Division 4 (Appendix E). PRC §4373 requires those facilities to maintain a clearance of flammable material for a minimum distance of 150 feet from the periphery of any exposed flammable solid waste.

Leachate

The operator shall ensure that leachate is controlled to prevent contact with the public.

As defined in §20164, "leachate means any liquid formed by the drainage of liquids from waste or by the percolation or flow of liquid through waste." Leachate can contain pathogens, heavy metals, and a variety of organic chemicals including known carcinogens such as benzene and vinyl chloride.

An observed or suspected leachate problem should immediately be brought to the attention of the appropriate RWQCB staff contact. Through consultation with the RWQCB and the CIWMB, a determination should be made about whether interim actions are needed, pending test results, to contain the suspected leachate. If the inspector has evidence that waste is in contact with groundwater or observes waste in contact with surface or groundwater (e.g., in trenches) this should also be communicated to the RWQCB.

During inspection preparation and review of the facility files the inspector should contact the appropriate staff person at the applicable RWQCB to determine if they have discovered problems with the facility's leachate collection and recovery system and/or leachate management program and whether there are enforcement or corrective actions in effect. This information, in conjunction with field observations, is used in evaluating the operator's compliance with the leachate standard and might be included in an inspection report.

Inspectors should always make their own observations during the inspection and document any observations supporting or expanding on the status of the facility's leachate collection and recovery system and/or leachate management program. The following guidance should be applied to possible leachate violations:

A violation of this standard will exist if:

1. The inspector observes liquid that has percolated through waste and flowed beyond the permitted boundary of the site.
2. Leachate management practices result in potential contact of leachate with humans.
3. Required leachate monitoring, control, and/or treatment systems are determined to be deficient or nonfunctional on the day of the inspection.

An "area of concern" will exist if:

1. Liquid that has percolated through waste is observed flowing or ponding on fill slopes, but is not migrating beyond the permitted site boundary (in such cases other standards may apply, e.g., grading).
2. During the perimeter walk the inspector has reason to suspect that surface water leaving the site boundary is contaminated to its appearance, odor, or location.

Again, if any of these conditions are observed during the inspection and RWQCB staff is not present the issue should be referred to the regional board for resolution.

Note: Water quality impairment can also occur when constituent compounds found in landfill gases are transferred to groundwater through gas migration.

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Dust

The operator shall take adequate measures to minimize the creation of dust and prevent safety hazards due to obscured visibility.

Throughout the inspection the inspector should evaluate dust control measures being taken by the operator. Dust control measures should be described in the JTD. If excessive dust is observed and the operator has taken no steps to control it (e.g., using a water truck) the facility is violating this section.

One or more of the following may be an indication that dust is excessive: (1) safety hazards due to obscured visibility; (2) irritation of the eyes; (3) hampered breathing; or (4) migration of dust off site.

Since this section was written, it has been determined that part of this requirement is within the jurisdiction of Cal-OSHA. Therefore, where the only impact is to personnel health and safety a referral should be made to Cal-OSHA. The RWQCB should be informed when new measures are proposed that include the use of leachate for dust suppression or irrigation. An area of concern may be considered if the site has numerous violations concerning dust control issued by the APCD or AQMD and/or a recent history of citizen complaints, but the inspector does not observe a violation of this standard during the inspection.

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