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HomeMy WebLinkAboutDSHW-2024-009573[Date] Piute County Special Service District #1 Attn: Kali Gleave, County Clerk P.O. Box 99 Junction, UT 84740 RE:Compliance AdvisoryNo. 2412146Compliance Evaluation Inspection of the Marysvale Class IVb LandfillSW147 Dear Ms. Gleave: This Compliance Advisory is being sent to your attention as a representative of Piute County Special Service District #1(the Respondent). According to the Division of Waste Management and Radiation Control’s (Division) records, you are the designated contact person for the Respondent. On December 3, 2024, representatives of the Division conducted a compliance evaluation inspection at the Respondent’s facility. The scope of the inspection was to verify compliance with permit 9503R3,Utah Administrative Code R315 (the Rules), and the Utah Solid and HazardousWaste Act (the Act). 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 violations: Utah Administrative Code R315-303-3(8)(a) requires“fencing at the property or unit boundary or the use of other artificial or natural barriers to impede entry by the public and large animals.” The facility permit Section III.B.1.c states the facility shall “Construct all fencing and any other access controls to prevent access by persons or livestock by other routes.”At the time of the inspection fencing by the entrance gate had been pulled back. Evidence of livestock entering the facility through the opening was visible. Requested Corrective Action: Please repair fencing to prevent public and large animals from entering the facility.Utah Administrative Code R315-303-4(7)(b)(iii) requires “a training program for the facility employees in identification of prohibited hazardous waste and prohibited waste containing PCBs.”The facility permit section III.C.1 requires “The Permittee shall provide training for on-site personnel in landfill operation, including waste load inspection, hazardous waste identification, and personal safety and protection.” At the time of the inspection trainings were not performed. Requested Corrective Action: Please implement a training program for on-site personnel that includes landfill operation, waste load inspection, hazardous waste identification, prohibited waste containing PCBs and personal safety. Please keep a record of trainings in accordance with the facility permit section III.H.3.d.Utah Administrative Code R315-303-4(2) requires “An owner or operator of a landfill shall operate the facility to: (c) collect scattered litter as necessary to avoid a fire hazard or an aesthetic nuisance.” At the time of the inspection litter was observed along the outer western perimeter and a large pile of green waste was observed dumped southwest of the entrance gate. Requested Corrective Action: Please clean up the litter and move the pile of green waste.Utah Administrative Code R315-320-3(2)(c) requires “Landfill Management of Whole Waste Tires. A landfill may not receive whole waste tires for disposal except as follows: (c) waste tires with a rim diameter greater than 24.5 inches may be disposed of in a landfill.” At the time of the inspection tires with a rim diameter less than 24.5 inches were observed in the working face of the landfill. Requested Corrective Action: Please remove the waste tires from the working face and place them in the facility’s waste tire pile.The facility permit section III.F.1. requires “The Permittee shall visually inspect incoming waste loads to verify that no wastes other than those allowed by this permit are disposed in the landfill. The Permittee shall conduct a complete waste inspection at a minimum frequesncy of 1% of incoming loads, but no less than one complete inspection per day. The Permittee shall select the loads to be inspected on a random basis.” At the time of the inspection random inspections were not conducted. Requested Corrective Action: Please implement random inspections of loads entering the facility.The facility permit section III.F.4.e. requires “The personnel conducting the inspection shall record the results of the inspection on a waste inspection form as found in Attachment #3. The Permittee shall place the form in the daily operating record at the end of the operating day.” At the time of the inspection random inspections were not recorded. Requested Corrective Action: Please record random inspections and include them with the daily operating record. Pursuant to this Compliance Advisory, the Director is providing the Respondent an opportunity to correct the apparent violations. 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 violation and associated corrective actions to the Director: the cause of each violation; 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 violations 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: dwmrcsubmit@utah.gov If the Respondent’s response is submitted by email, please confirm submission by receipt of an autoreply email.DO NOT submit any documents or information through email that are confidential, proprietary, or for which the Respondent claims business confidentiality pursuant to the procedures in Utah Code § 63G-2-309(1)(a)(i). To better protect confidential or protected records, all such documents and information must be submitted in paper form, using the U.S. Mail address above. Note that the Division classifies all records relating to an enforcement matter, including this Compliance Advisory, as being protected during the pendency of the matter, pursuant to Utah Code Section 63G-2-305(10). However, once the matter is closed, this protected classification no longer applies. 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 contactKelly Shaw at 385-454-5832. Sincerely, Douglas J. Hansen, Director Division of Waste Management and Radiation Control DJH/KMS/[???] Enclosure(s): c:Local health Department (go to U:\HW General Folders\Local Health Depts and Dist. Engineers and insert correct health department file) List all other persons who are to receive copies, including division staff. List email addresses next to the names of persons who are to receive a copy via email. List mailing addresses next to the names of persons who are to receive a hard copy.