The Ohio Environmental Protection Agency slapped Envirosafe Services of Ohio, Inc., (ESOI) with a $180,000 penalty for multiple hazardous waste management violations at its landfill in Oregon.
The violations, according to Dina Pierce, northwest district media coordinator with the Ohio EPA, occurred between 2007 to 2009.
“Ohio EPA conducts compliance inspections twice a year at the facility,” explained Pierce. “Ohio EPA also has an on-site inspector based at the facility who conducts daily compliance inspections of Envirosafe’s operations. Some violations were found by the on-site inspector during daily inspections, others during the annual inspections and some were reported by ESOI.”
The $180,000 fine covers multiple inspection and record keeping violations involving the containment building, the water line dewatering trenches and the Cell M leachate collection system at Envirosfafe, said Pierce.
They violations include:
• failing to properly operate leachate collection sump pumps;
• failing to properly operate the liquid collection and removal system around the stabilization containment building;
• failing to report the exceedance of leakage rates for the stabilization containment building or failing to remove liquids from the building’s sumps within 30 days;
• failing to implement the containment building response action plan as required by the facility’s permit and failing to record and maintain a record of the volume of liquids removed from each sump;
• failing to conduct several permit-required inspections or failing to make a record of inspections;
• failing to notify Ohio EPA and U.S. EPA in writing that the liquid level in a containment building sump had not returned below a leakage rate level and failing to modify the facility’s response actions to make them more effective in reducing liquid levels in the sump;
• failing to keep liquid levels in the dewatering trenches around the city of Toledo water lines below the bottom of the water lines. At no time did leachate in the trenches enter the water lines.
The dewatering trenches, which run parallel to the Toledo water lines, are located between the water lines and the hazardous waste disposal cells on ESOI property. The trenches were dug to a depth of at least one foot below the adjacent water lines. The dewatering trenches were then filled with stone to collect liquids before they come into contact with the adjacent water lines, said Pierce.
“The purpose of the dewatering trenches is to prevent contaminated liquids from coming into contact with the water lines,” said Pierce. “As a result of the settlement, ESOI is now required to monitor the level of liquids in the dewatering trenches three times a week. If ESOI observes liquid in a dewatering trench within one foot of the elevation of the adjacent waterline, ESOI is required to pump the liquid out of the dewatering trench. Although Ohio EPA believes the possibility of contaminated liquids penetrating the water lines is very small due to the water lines being under pressure, this requirement further reduces the possibility of contaminated liquids coming into contact with the water lines.”
Depending on the equipment or operation, ESOI is required to conduct daily, weekly, monthly, quarterly, semi-annual and annual inspections, said Pierce. Some parts of the containment building are inspected multiple times a day. The water line dewatering trenches are now inspected three times a week. Parts of Cell M’s leachate collection system are inspected twice a day.
More violations covered poor management practices and record keeping, failing to properly label railcars and containers of used oil and failing to properly report all instances of exceedances or noncompliance with the facility’s permit conditions.
In addition to the $180,000 penalty, the company is required to make modifications to the facility’s permit to improve the monitoring, operation and maintenance of the leachate collection systems, improve inspections, record keeping and reporting requirements of the water line trench monitoring program, clarify the notification requirements of the containment building Response Action Plan, and conduct leak testing around the containment building sump and submit the results to Ohio EPA.
Envirosafe also has to submit documentation that its staff involved in the measurement and removal of liquids from the raw water line trench sumps has been properly trained, according to Pierce.
Most of the violations have been resolved.
“Envirosafe has already changed its operations to correct most of the violations,” said Pierce. “This was required in our settlement. Many of the improvements were accomplished through modifications to the facility’s permit in order to add clarity to the permit requirements for inspections, record keeping and reporting.”
Other permit modifications include a modification to re-size the pumps in Cell M’s leachate collection system to improve efficiency and reduce breakdowns, and implementing an even more proactive plan for pumping the waterlines’ dewatering trenches, said Pierce.
A copy of the settlement is available online at www.epa.ohio.gov/dhwm/2010aco.aspx.