DSHW-2024-005863

May XX, 2024
Garfield County
Attn: David Dodds, Public Works Director
P.O. Box 77
Panguitch, UT 84759
RE:Compliance Advisory No. 2404070Compliance Evaluation InspectionSW242
Dear Mr. Dodds:
This Compliance Advisory is being sent to your attention as a representative of Garfield County(the Respondent). According to the Division of Waste Management and Radiation Control’s
(Division) records, you are the designated contact person for the Respondent. OnApril 16, 2024, a representative of the Division conducted a compliance evaluation inspection at the Respondent’sGarfield
County Dead Animal Pit Class IVb Landfill (Landfill). The scope of the inspection was to verify compliance with Utah Administrative Code R315 (The Rules), the Utah Solid and Hazardous
Waste Act (the Act), and the active Permit for the Landfill, issued February 26, 2021 (DSHW-2021-001086).
Based on observations and information obtained during the inspection, the Director of the Division (Director) is issuing this Compliance Advisory to provide the Respondent with notice
of the followingcompliance issues as well as an opportunity to correct these apparent compliance issues: Utah Administrative Code R315-303-3(7)(d)requires “erecting a sign at the facility
entrance that identifies at least the name of the facility, the hours during which the facility is open for public use, unacceptable materials, and an emergency telephone number”.
Upon arrival at the Landfill, the inspector did not observe any signage indicating the location of the dead animal pit.
Requested Corrective Action: Please submit photographs demonstrating acceptable signage is in place. The signage should identify at least the name of the landfill, the hours of operation,
unacceptable materials, and an emergency telephone number.Utah Administrative Code R315-315-6(2)(b)requires “if dead animals are disposed in a separate trench, at a permitted facility,
the carcasses shall be completely covered with a minimum of six inches of earth at the end of the working day the carcasses are received”.
The inspector did not observe adequate coverage of the dead animals resulting in birds scavenging the Landfill.
Requested Corrective Action: Please submit photographs demonstrating the dead animals are completely covered with a minimum of six inches of earth at the end of the working day the carcasses
are received.
Pursuant to this Compliance Advisory, the Director is providing the Respondent an opportunity to correct the apparent compliance issues. The Director will also consider any evidence
and additional information provided by the Respondent.
Within 30 days of the date of this Compliance Advisory, please submit the following requested documentation regarding each compliance issue and associated corrective actions to the Director:
the cause of each compliance issue;
the specific corrective actions taken, results achieved, and applicable dates;
if future corrective actions are proposed, the specific corrective actions and proposed completion dates, including intermediate milestones, as applicable; and
how the corrective actions will prevent similar compliance issues from recurring.
All information regarding corrective actions relating to this matter should be addressed to the Director at:
Douglas J. Hansen, DirectorDivision of Waste Management and Radiation ControlP.O. Box 144880Salt Lake City, UT 84114-4880or by email at: [e-mail]
DO NOT submit any documents or information through email that are protected, confidential, proprietary, or for which you are claiming business confidentiality under Utah Code § 63G-2-305.
To better ensure records are protected, all such documents and information must be submitted using the mailing address above and
in accordance with Utah Code § 63G-2-309.
If the Respondent demonstrates that it has taken appropriate corrective actionsregarding the matters addressed in this Compliance Advisory, the Director will issue a closeout letter
and will consider this matter to be closed.However, if the Respondent fails to demonstrate appropriate corrective actions within the30-day timeframe, the Director will consider taking
escalated enforcement actions, including seeking financial penalties. In all events, the matters addressed in this Compliance Advisory, including the Respondent’s corrective actions,
will become part of the Respondent’s compliance record and may be considered in connection with future enforcement matters.
If you have any questions, please contact Alex Milne at [e-mail] or by phone at [phone].
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/AM
Enclosure(s):Inspection Report (DSHW-2024-XXXX)
c:Jeremy Roberts, Environmental Health Director, Southwest Utah Public Health Department
Paul Wright, P.E., District Engineer, UDEQ