Wednesday, July 24, 2019

Advanced Disposal Landfill Tracking Non-compliance


 ADEM (Alabama Department of Environmental Management)
has blocked all of my complaints sent today. With that said, I will publish them publicly.  




Citizen Compliant: 07/24/19


Please accept this citizen complaint on behalf of Hurricane Creekkeeper and Friends of Hurricane Creek regarding Advanced Disposal Landfill Land permit #63-16 and NPDES ALG160090.

 A recent consent order response was posted to ADEM E-file site, which included a few issues I'd like to address.
 "In order to further prevent offsite tracking, Eagle Bluff Landfill proposes to design and install a wheel wash. If their tires require cleaning, customer trucks will be required to pass through the wheel wash after disposing of their load and prior to exiting the facility. The proposed wheel wash system will be self-contained, and no water will be allowed to discharge from this system. Any solids that accumulate within this system will be removed and placed in the landfill area. Any liquid that is required to be removed will be disposed at a proper disposal facility. At no point will liquid from the wheel wash system be allowed to discharge through the storm water drainage system."
I am pleased that ADLF finally admits they need to address tire tracking. It has been a chronic issue for years and the violations basically ignored by ADEM until recently. With that said there are a couple of things that need to be addressed. According to the report ADLF intends to install the tire wash by Dec. 31, 2019. This is unacceptable since there are many plans and even installation companies that do this type work on a regular basis. In less than 15 minutes I was able to locate such companies and plans online. (https://www.tirewash.com/) ADLF has shown in the past that these delay tactics only facilitate further non-compliance. ADEM has a responsibility to enforce the rules even while ADLF delays compliance with the current consent order. Recent rain events have proven once again that as long as ADEM gives extremely long time frames to reach compliance the landfill will take full advantage. ADEM needs to inspect frequently and without prior notice to ADLF personnel for compliance given the history of non-compliance at this facility. The order issued to ADLF clearly states that they must comply with permit requirements during the arbitrary time frame set forth to correct past issues.
In the consent order there is a clause that demands ADLF must maintain compliance with permit requirements. That included an adequate haul road that prevents offsite tracking. 

On 05/25/19 ADLF applied a few loads of rock to the haul road and one pile was left in the drain flow of a seep previously noted. On 06/05/19 Inspector Johnson took a photo of the segment of haul road directly in front of the office as if to indicate that the whole road looked like that. It was far from accurate. To date, that was the last time the so-called haul road was addressed. As of today, it has reverted back to the red mud it was before. Every truck entering the ADLF with clean tires comes out covered with mud during even minimal rain events. As stated dozens of times before, the sweeper is doing nothing more than spreading the mud to the side of the road where it runs off into the unnamed tributary along 12th street. In a short time in the sun, the mud becomes overwhelming dust clouds. 
At this time ADLF is in violation of said order. 

















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