DSHW-2024-005998

May XX, 2024
Wayne County Sanitation Special Service District
Attn: Scott Chesnut, Landfill Supervisor
18 South Main Street
P.O. Box 189
Loa, UT 84747
RE:Compliance Advisory No. 2404083Compliance Evaluation InspectionSW113
Dear Mr. Chesnut:
This Compliance Advisory is being sent to your attention as a representative of Wayne County Sanitation Special Service District (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’s Wayne County Long-Hollow Class II 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 October 1, 2015 (DSHW-2015-009955).
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 R315-303-4(4)(a) requires “an owner or operator of a
landfill shall, at the close of each day of operation, completely cover the waste with at least six inches of soil or an alternative daily cover as allowed in Subsections R315-303-4(4)(b)
through R315-303-4(4)(e)”.
The inspector did not observe adequate coverage of the waste at the Landfill. Large piles of both C&D waste and MSW waste were exposed.
Requested Corrective Action: Please submit photographs demonstrating adequate coverage of waste within the designated cells.Utah Administrative Code R315-302-2(2)(h) requires “a plan
to control wind-blown litter that includes equipment and methods to contain litter, including a schedule and methods to collect scattered litter in a timely manner”.
The inspector did not observe an adequate plan to control wind-blown litter was in place. Wind-blown litter was scattered throughout the landfill property, along fencing, and outside
of the landfill’s property boundary.
Requested Corrective Action: Please submit photographs demonstrating adequate controls for wind-blown litter are in place including collecting the wind-blown litter scattered throughout
the landfill property. Additionally, submit photographs of the wind-blown litter scattered beyond the landfill boundary have been collected. Utah Administrative Code R315-302-2(2)(g)
requires “a plan to control fugitive dust generated from roads, construction, general operations, and covering the waste”.
The inspector did not observe an adequate plan to control fugitive dust was in place. The inspector was informed by Scott Chesnut, Landfill Manager, that water trucks are utilized in
the summer for fugitive dust control, however, it appears the seasonal use of water trucks may not be enough to prevent the excessive generation of fugitive dust.
Requested Corrective Action: Please submit photographs demonstrating adequate controls for wind-blown litter are in place including collecting the wind-blown litter scattered throughout
the landfill property. Additionally, submit photographs of the wind-blown litter scattered beyond the landfill boundary have been collected. Utah Administrative Code R315-303-3(1)(b)
requires “an owner or operator of a landfill to prohibit the disposal of containerized liquids larger than household size, noncontainerized liquids, sludge containing free liquids, or
any waste containing free liquids in containers larger than household size”.
The inspector was informed by Scott Chesnut that the facility has been receiving approximately 2,000 gallons of untreated sewage for disposal at the Landfill. The inspector observed
free liquids as a result of sewage acceptance onto the native soils. Manifests or other documentation for the sewage waste were requested and not received to date.
Requested Corrective Action: Please cease the unauthorized acceptance of sewage waste. If you would like to continue accepting sewage, the Division will require a major permit modification
application that will need to include details to meet the following requirements:
Application Location Standards of R315-302-1;
Plan of Operation Requirements of R315-302-2(2);
Performance Standards of R315-303-2; and
Either the liner standards of R315-303-3 with groundwater monitoring wells and a monitoring plan according to R315-308 or propose a double-lined cell with leak detection instead of monitoring
well; OR
The prompt management of sewage waste by mixing the soils to pass the Test Method 9095B, Paint Filter Liquids Test, as provided in EPA Publication SW-846, "Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods" available at the US EPA Hazardous Waste Test Methods/SW-846 website.
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:Inspection Report (DSHW-2024-XXXXX)
c:Nathan Selin,Health Officer, Central Utah Public Health Department
Eric Larsen, Environmental Health Director, Central Utah Public Health Department
Jason Bagley, Environmental Health Scientist, Central Utah Public Health Department
John Chartier, P.E., District Engineer, UDEQ