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I CIWMB Forni 53 · Transfer/Processing Facility Inspect~on Report Enforcement Agency: California Integrated Wasl~_ Management Board ' - -', - Facility Name: Community Recycling and.~es()urce Recov~ry,lno. Facility File Number: 19--AR-0303 Inspection Date: 12106/2008 " . Page 2 of 4 Comments Continued: o a e, e s no ma e a na eterm n8 on nor a8 e perm Ing an enwonman a ocumen a on requeste by the Local Enforcement Agency (LEA) been compteted. As a result. the operator continues to conduct solid waste handling activities on the unpermitted southwest property while the pennitting and environmental documentation requested by the LEA are being completed. The IHP requested the LEA and operator to develop an Interim Operating Agreement (lOA) to establish operational rules for the acUvlUes during the permitting process. The IDA was signed by the lEA and operator on April 19. 2007. A revfsed Major Milestone Task Schedule, dated September 11, 2008, was submitted by the operator to the LEA. According to the schedule, the Draft EIR was to be p~bllshed (for pUblIc comment) In October 200B. It Is CIWMB staffs understanding that the Draft EIR has not yet been completed. The operator needs to work with the LEA to provide an updated schedule for the preparation and circulation of the Draft E1R in order to ensure that progress Is made to revise the SWFP to accurately reflect the activities being conducted at this facility. If the operator wishes to make a change to the design or operation of their faelllty that Is not authorized by the existing SWFP, the operator Is required to file an application to revise (or modify) the SWFP at least 180 days ~ making the change (PRe 44004). If the LEA determines that an operator has changed the design or operation from that which Is authorized by the eXisting SWFP, the LEA Is required to pursue enforcement as provided In its enforcement program plan (e.g., Issuance of a notice and order. cease and desist order, etc.. PRO 45000 at. seq.). ~ation' PRe 44014(b) - Terms and CondlUons of the SWFP . The operator fs required to comply with all the terms and conditions of the SWFP. In addition to the Increased acreage of the facility as described above, the operator has also Increased their daily tonnage throughput above the permitted limit. The SWFP allows for a maximum of 11700 tons per day (tpd); however, the facility is receiving up to an addiUonal2,900 tpd at the unpermitted southwest property (1,200 tpd of source separated green material, 1,200 tpd of source separated CDI, 350 tpd of source separated supermarket trim and cull matenals, and 150 tpd of source separated wood waste (as provided In the lOA)). A review of the tonnage records for july, August, and September 2008, document that the total tonnage received at the facility , (permitted and unpermitted areas) consistently exceeded the permitted maximum of 1,700 tpd. CIWMB staff W!!S Informed by the LEA that the operator Is working with the local planning department on a Draft EIR. Including an analysis of the total tonnage received at the site. Violation: 14 CCR 17403.9. Transfer/Processing R~port. Tile governing document for the site Is the June 20, 1997 Report of Station Information (see SWFP Section 16). There have been several changes In the operation that are not accurately reflected in the June 20,1997 Report of Station Information, or subsequent RFI Amendments filed and approved as Indicated above (and Note 2 below). It Is CIWMB staffs understanding that the operator plans to revise the SWFP to incorporate the unpennitted. southwest property and tonnage into a revised SWFP. As part of the SWFP application process, the operator will be required to submit a transfer/processing report that accurately reflects the operations at the facility and contains the Information as required by 14 CCR 18221.6. ~tlon: 14 CCR 17407.2. Cleaning.. CIWMB staff arrived at the site at 0330 and observed IIlter and loose debris under the resource recovery equipment, In belween and hanging (rom the conveyor belts, and in the loading pit. There was a layer of soot on the tipping fioor as well as under and around the resource recovery equipment. Utter and loose materials are required to be cleaned each operating day or for facilities that operator 24 hours per day at least once every 24 hours. Based on CIWMB staff's observaUons, nUer and loose materials were not adequately cleaned within the last 24 hours. SWFP condition 17.A.8. requIres that the operator ensure dally litter plck..up in addili~n to daily sweeping of the entire transfer facility. In addition. the August 22. 20D8 Alternallve Odor Management Plan. which was filed as part of a RFf Amendmentln September 2008, details the dally cleaning requirements. ~: 14 CCR 17407.5. Hazardous. liquid. and Special Waste - Hazardous waste recovered from the waste stream Is stored on the ground in a temporary chain link fence enclosure behind the equipment storage building. No secondary containment or signage was observed. Hazardous waste recovered must be handled and stored to protect public health. safety and the environment. The operator Is encouraged to work with the local certified unified program agency (CUPA) on the proper handling and storage of recovered hazardous waste. 88 Page 13~ i ~ I I I I I ! 1 i I j 1 i i ! i I j I 1 1 I ~ ~...w j I i I I I i i I i ! ( ! I r j I I I I i-