Asbestos NESHAP Inspection and Safety Procedures Course Chapter

Asbestos NESHAP Inspection and Safety Procedures Course Chapter Fifteen Landfill Inspections 2014

Topics n n n Owner/operator responsibilities Targeting waste disposal sites Planning the inspection Recordkeeping requirements Reporting requirements Inspection activities 2

Owner/Operator Responsibilities Owner/Operator Subject to: Title Generator § 61. 150 Standard for waste disposal… WDS Operators § 61. 10 Source reporting § 61. 153 Reporting § 61. 154 Standard for active waste disposal sites 3

Targeting Waste Disposal Sites Landfill lists n Notifications n Previous inspection reports n 4

WDS Inspection Planning n n n n Gain familiarity with required records Review agency files Communicate with other agencies/departments Acquire site information Plan inspection (time, deposition) Accumulate inspection materials Devise sampling strategy for records See Checklist in Appendix D of course notebook 5

WDSs must maintain: n Waste shipment records (WSRs) n ACWM deposition information 6

Waste Shipment Records n Records the following information: n n n n Work site name/mailing address Operators name/address Name/address of responsible agency Description/amount of ACWM Operators certification Certification of receipt by transporter(s) Indication of discrepancies Certification of receipt by waste disposal site 7

Verify WSR Information n Certify receipt and return copy to generator (30 days) Maintain file copy (2 years) Provide information upon request 8

ACWM Deposition Recordkeeping n Maintain until closure a map or diagram with: n n n Location Depth and Area Quantity 9

WDS Reporting Requirements n Stationary source report n Discrepancy reports n Improperly contained waste report n Excavation/disturbance report n Closure report 10

Stationary Source Report n n n Submit by 2/18/91 or within 90 days of startup Description of site Methods employed to ensure compliance Name/address of owner or operator Average weight/month processed during previous 12 months 11

Discrepancy Reports n n n Describe discrepancy in Item 12 of WSR Attempt resolution If no resolution within 15 days, submit written discrepancy report to agency(ies) responsible for generator and waste disposal site n Description of discrepancy n Steps to resolve n Copy of WSR 12

Improperly-Contained Waste Report n n Describe improperly contained waste in Item 12 of WSR Submit written report by following working day to agency(ies) responsible for job site location and disposal site n n Copy of WSR Detailed description of improperly enclosed or uncovered waste 13

Excavation/Disturbance Report n n Written notice 45 days before activity Notice must state: n n Scheduled starting / completion dates Reason Planned emission control procedures Location of temporary storage site and final disposition site 14

Change in Activity Date? n n Notify at least ten days in advance for later start date Earlier start date not permitted 15

Asbestos Disturbance 16

Closure Report n n Submit map or diagram of disposal area containing disposal information to Agency Notate deed within 60 days of closure n n n Land used for ACWM disposal Reference to information filed with Administrator Reference to site being subject to Asbestos NESHAP 17

Landfill Inspection Activities n n Preliminary interview Reviewing records Site observations Post inspection interview 18