failure to respond to this letter in writing shall be ... · re: permit nbr. 0273-s3n afin 04-00107...

June 13, 2006

Mr. Scott Carney Southwest Electric Co. Power Co. Rt. 2, Box 835 Gentry, AR 72734

RE: Permit Nbr. 0273-S3N AFIN 04-00107

Dear Mr. Carney:

On May 12,2006, I performed a routine inspection of your facility pursuant to the Arkansas Solid Waste Management Reg. 22, and the above referenced permit. A copy of the inspection report is enclosed for your review.

Refer to the report to note any allegations of deficiencies that require corrective action. Please send a written response to the corrective action taken. Failure to respond to this letter in writing shall be construed as an admission of any allegations contained therein. Any items noted that are neglected and persistent may warrant enforcement action.

If I can be any further assistance, feel free to contact me at (479) 452-4822 ext. 12, or P. O. Box 11045, Fort Smith, AR 72917-1045.

Sincerely,

Justin Sparrow, Inspector Solid Waste Management Division

xc: Central Files Enforcement Branch Files, SWMD

D:\INSPECTOR FILES\INSPECTIONS\CLASS 3\3 N\0273-S3N\LETTER\SWEPCO INSPECTION LETTER.DOC

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June 14, 2006

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Document ID # - 34881

Class 3 Lf Form 1997/ Rev. Jan. 2003 / Rev 8-19-03 FOR ADEQ USE ONLY G Copies requested by____________________ Data Entry Number_______________

Arkansas Dept. of Environmental Quality Solid Waste Management Division

Class 3 Landfill Inspection

Site Name: Swepco- AEP County: Benton AFIN: 04-00107

Location: Benton CR 489 Telephone Number:

(479) 736-2626 Permit No.: 0273-S3N

Address of Permittee:

Rt 2, Box 835 Gentry, AR 72734

E-MailAddress:

Licensed Operator & No: Scott Carney

Regulation 22 - Operational Standards

Category 1 First Violation: Score of 1Second Violation: Score of 2Third Violation : Score of 3

Category 3 First Violation : Score of 3Second Violation : Score of 6Third Violation : Score of 12

Adequate employee facilities 510(l) Operations in accordance with permit documents 510(a)Record keeping meets requirements specified by regulations 520(a)(b) Gas monitoring program 514 Feeding of farm or domestic animals prohibited 510(f)(2) Facility implements operating plan and narrative 521 Salvage operations meet approved conditions 510(e) Hazardous waste exclusion plan 511 Required facilities, fencing and information signs posted 516(b) Satisfactory daily/alternative cover 512(a)(b) Access confined to hours of operation 516(d) Open burning prohibited 515(b), 510(f)(4) Scavenging of waste prohibited 510(f)(1) Cause discharge 518 Proper wet weather repairs 510(o) Leachate disposal records 520(a)(4) Operations by licensed on-site personnel at all times 510(b) Special waste disposal and procedures records 701, 520(a)(2) Waste spread and compacted as unloaded 510(d) Depositing waste in standing water prohibited 510(f)(3), 518(a)(4) Adequate all weather operational roads 516(c) Erosion or other cover defects resulting in exposed refuse 510(n) Adequate provisions for backup equipment 510(j) Leachate leaks or evidence of leachate seepage 510(n) Waste receipt records, ticket system maintained 520(c) Satisfactory intermediate cover 512(c) Telephone system and written emergency response plan on site 510(k) Leachate discharge leaving landfill 518(a)(5)

Category 2 First Violation: Score of 2Second Violation: Score of 4Third Violation : Score of 8

Adequate access control 516(a) Smallest practical area, unloading supervised, single working face 510(c) Litter control provisions maintained 510(g) Disease vectors controlled 513(a) Contouring prevents surface water flowing into or through waste 510(h)(1) Plans and narrative updated to reflect current operation 521(c) Annual compliance inspection by registered professional engineer 522(a) Run-on/run-off control system present and adequate 517(a)(b) Surface water control prevents off-site sediment accumulation 510(h)(2) Landfill compliance with liquid restrictions 519 Adequate maintenance of final cover vegetation 510(i)

Comments:

No violations noted at time of inspection.

The Solid Waste Division Facility Review was conducted in conjunction with this inspection. See notes and photos attached.

YTD Facility has landfilled 8498.16 Tons, and removed 12133.83 Tons.

Entry Time: 0930 Date: 5-12-06

Exit Time: 1130 Total Hours: 2.5

INSPECTION FREQUENCY BY SCORE: 0-16 Quarterly Inspection

>17 Monthly Inspection

TOTAL SCORE:

0

Regulation 22 - Records

520(a)(8), 204(b) Date of last groundwater monitoring report Date of last engineering report

520(a)(8), 528(h) Date of last liner certification report

511 Date of last random inspection for hazardous waste Total # for month

514, 520(a)(3 Date of last quarterly methane monitoring Detection level

701, 520(a)(2) Date of last special waste received Disposal location

520(a)(4) Date of leachate disposal Method Location

520(c) Last months reported waste received Tons Cy

Person interviewed if applicable:

Scott Carney

Signature of Inspector:

Arkansas Department of Environmental Quality - Facility Evaluation Comments Page

Name of Site: SEPCO Class III Landfill- Gentry

Date:5/12/06

County: Benton

AFIN:04-00107

Permit No.: 0273-S3N

This inspection was made in conjunction with the Solid Waste Division Facility Review. Present at this review was Scott Carney, Regional Environmental Coordinator, Terry Wehling, Engineer I, Heidi Love, ADEQ Inspector Supervisor, and I.

At the time of this inspection, no violations were noted. However, the facility is currently in the process of a major modification to their permit. The Solid Waste Technical Branch is working with the Facility to resolve a few issues that were discussed on the date of this inspection.

There is some question whether the facility has filled over the original boundary. While the original permitted area included the fenced 40 acres, it appears there has been some filling on the West side of the landfill above the original berms constructed around the landfill.(No material seems to have been placed outside the original 40 acre permitted site.)

Also, according to Mr. Wehling, the Facility’s groundwater monitoring sampling program has revealed some affect on the groundwater sampled from the monitoring well located at the NW corner of the landfill. SWEPCO is currently working with the Solid Waste Division Technical branch to study this situation.

At the time of this inspection, Mr. Carney and Mr. Wehling conducted a tour of the Landfill, and surface water control measures the facility has in place; including the primary and secondary sedimentation ponds, NPDES permit discharge location, and bottom ash collection areas.

On September 26, 2005, the Facility submitted an application for a Permit Modification.However, the Department has not approved the modification due to deficiencies in the application. These deficiencies were listed in a Department letter dated April 6, 2006. As of this date, the Facility has not responded to this request for information regarding the application.

Revised Jan 2003 FOR ADEQ USE ONLY

Arkansas Department of Environmental Quality (ADEQ)Official Photograph Sheet

Location: SWEPCO Class III Landfill- Gentry

Photographer: Justin Sparrow Witness: Heidi Love

Photo # 1 Of 25 Date: 5-12-06 Time: 1000

Description: West slope of the landfill.



Description: View across the Landfill from the West facing East.





Description: North edge of the Landfill.



Description: Survey marker at the NW corner of the Landfill.





Description: View of the North slope of the landfill.



Description: Groundwater monitoring well located @ 65’ N of the NW corner of the Landfill.





Description: Groundwater monitoring wells on the North edge of the landfill.



Description: View from the NE corner of the landfill.





Description: View of the plant from the NE corner of the Landfill.



Description: Survey marker on the NE corner of the Landfill.





Description: Water truck used to wet the Fly Ash to cool and solidify the material.



Description: Runoff area on the SE corner of the Landfill leading to the Primary Sedimentation pond.





Description: Blower truck and small bag house used to load sold fly ash into rail cars for shipping.



Description: Dump truck for hauling Fly Ash from the plant to the Landfill.





Description: Bulldozer used to move coal in the reserve area.



Description: Discharge pipes from boiler carrying Bottom Ash into primary sedimentation pond.





Description: Facility is constructing the Primary Sedimentation pond to increase water retention time.



Description: Construction on the Primary Sedimentation pond.





Description: Local Resident relaxing on the weir between the Primary and Secondary Sedimentation pond.



Description: View of Primary Sedimentation pond from weir.




Photo # 21 Of 25 Date: 5-12-06 Time 1000

Description: Weir between Primary and Secondary Sedimentation Ponds.



Description: NPDES Discharge and Sampling site.





Description: CO2 being added at the final NPDES discharge point to reduce the Ph of discharged water.



Description: View of the plant from the NPDES discharge site.





Description: View of the landfill from the NPDES discharge site.

Photographer: Witness:

Photo # Of Date: Time:

Description:

failure to respond to this letter in writing shall be ... · re: permit nbr. 0273-s3n afin 04-00107...

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