Document g2BVoZBkpmp51n95VZQw656GQ

REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Time: Media: Statute(s)/Program(s): Type of inspection: Access: 02/17/2022 - 02/17/2022 Announced: Yes Entry: 08:00 AM (ET) Exit: 10:30 AM (ET) Water Clean Water Act, NPDES CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) County/Parish: Facility GPS Coordinates: Mailing address: (If different) (City, state, zip code) Meigs County Commissioners - Meigs County Landfill Meigs County Landfill Howell Hill Cemetary Road Salisbury Township, OH Meigs County 39.05656, - 82.05073 100 East Second Street, Suite 301 Pomeroy, Ohio, 45769 Facility/Site Identifier: Permit Number: SIC or NAICS: Meigs OH0135038 9999 Persons Participating in Inspection: Title Name Phone Lead inspector Inspector Meigs County Engineer Andi Hodaj (312) 3534645 Jake Berger (312) 3538024 Eugene Triplett (740) 9922911 Email hodaj.andi@epa.gov Present at Opening Conf. Yes Present at Closing Conf. Yes berger.jake@epa.gov Yes Yes eugenetriplett.mchd@yahoo.com Yes Yes Lead inspector: Andi Hodaj ANDI HODAJ Region 5 Digitally signed by ANDI HODAJ Date: 2022.04.05 20:24:29 -05'00' hodaj.andi@epa.gov (312) 353-4645 Supervisor Review: Molly Smith MOLLY SMITH Digitally signed by MOLLY SMITH Date: 2022.04.05 20:33:49 -05'00' 1 of 9 Meigs County Landfill Inspection Date(s): 02/17/2022 - 02/17/2022 Region 5 Smith.Molly@epa.gov SECTION I - INTRODUCTION Site Entry and Inspection Objectives A CWA inspection at the closed landfill of Meigs County. Region 5 Lead inspector, Andi Hodaj, arrived at the Meigs County Landfill (the "Site" or "Facility"), located at Howell Hill Cemetary Road, at 08:00 AM (ET) on 02/17/2022 for an announced inspection. Region 5 Lead inspector presented his credentials to Eugene Triplett and informed him that this was an inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted by the Region 5 NPDES permit program, under the authority of Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Meigs County Landfill representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5 including: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by the Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made by information supplied by Meigs County Landfill representatives (the permittee) during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Meigs County Landfill representatives during or subsequent to the on-site Inspection. In addition, information gathered prior or subsequent to the Inspection from a review of EPA, State, and public records may be included in this report. Facility/Site Description Region 5 lead inspector confirmed the following facility information: Meigs County operated a municipal landfill at the site until 1988, at which time it stopped receiving waste. The landfill was subsequently capped with 18 inches of clay taken from a nearby area. Leachate from the landfill drains through a system of four-inch perforated pipes into a two-cell constructed wetland for treatment, before discharging into an unnamed tributary of Thomas Fork. Thomas Fork flows south approximately 10 miles into Ohio River. The capped landfill area is approximately 3.5 acres and each wetland cell has dimensions of 75 feet by 30 feet. Cell One of the wetland was lined with a geosynthetic bentonite clay liner and filled with 18 inches of gravel. Cell Two was constructed similarly to Cell One, except without the bentonite liner, and was capped with four inches of top soil. The cells are connected by four-inch polyethylene pipes. The water levels in Cell One and Cell Two are controlled by Agri Drain inline water level control structures. Discharge from Cell Two is regulated under an Ohio EPA issuedpermit, number OH0135038. Facility/Site Information Responsible official Eugene Triplett Do you use in-house or contract out for laboratory analyses? (including for metals or WET testing?) Contract out to Ream & Haager Environmental Laboratory Inc. Do you accept waste No from septage haulers? 2 of 9 Meigs County Landfill Inspection Date(s): 02/17/2022 - 02/17/2022 If so, what problems have you experienced? Is there currently any No portion of the treatment train that is non-operational? Are there any plans No for renovation or additional equipment to allow for increased wastewater flow? Unit(s) Unit/Area/Sub-area Landfill Description The landfill is located at Howell Hill Cemetary Road in Salisbury Township, Meigs County, Ohio, and includes a two-cell wetland that treats leachate from the landfill. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unit: Landfill Observation #: AH2-OB-001 Contains CBI: No Date: 03/25/2022 EPA arrived at the landfill area at approximately 8:45 a.m. Eastern Time where we met with Jim Freeman of Meigs County Soil and Water Conservation District. Mr. Freeman performs the sampling at the end of the wetland and submits the Discharge Monitoring Reports (DMR) to Ohio EPA. Mr. Triplett stated that two BioDiffusers were installed at the start and end of each Cell in 2021. EPA observed the two-cell wetland and the outlet of Cell Two where samples are taken, as required by the Facility's NPDES permit. EPA observed discharge from Cell Two and from the pipe discharging into the unnamed tributary of Thomas Creek at the time of the inspection. During the inspection, EPA observed less than an inch of water on the top of the wetland cells, which was gold/brown in color. Also during the inspection, EPA observed a sheen layer on the top of Cell Two. Mr. Freeman attributed the sheen layer on the top of Cell Two to a bacteria colony resulting from past mining activities in the area. The AgriDrain water level control structure at the start of Cell One was flooded at the time of the inspection and there was water pooling around it. Photo(s) 1. RIMG2475.JPG 2. RIMG2476.JPG 3. RIMG2477.JPG 4. RIMG2479.JPG 5. RIMG2480.JPG 6. RIMG2482.JPG 3 of 9 Meigs County Landfill Inspection Date(s): 02/17/2022 - 02/17/2022 SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Permit Ref #: AH2-RR-003 Reviewed By: Andi Hodaj AOC: Yes Reviewed Date: 03/28/2022 EPA reviewed the NPDES permit, number OH0135038, that was issued to Meigs County Commissioners - Meigs County Landfill ("facility") by Ohio EPA with effective date February 1, 2021, and expiration date January 31, 2026. Part I, C. of the permit contains a Schedule of Compliance that requires the facility to submit a plan to Ohio EPA that details any necessary construction or process changes to the treatment process to achieve compliance with the final effluent limits for ammonia. The compliance schedule requires the facility to implement the specific plan within 12 months of the effective date of the permit. At the time of the inspection, the facility had not submitted nor implemented the plan. Record: Laboratory Analysis Reports Ref #: AH2-RR-002 Reviewed By: Andi Hodaj AOC: No Reviewed Date: 03/28/2022 EPA reviewed laboratory reports for analysis of samples from Outfall 001 for the period January 2019 - January 2022. Samples were analyzed by Ream & Haager Environmental Laboratory Inc. and provided to EPA by Mr. Freeman on February 17, 2022. Record: DMR Reports Ref #: AH2-RR-001 Reviewed By: Andi Hodaj AOC: Yes Reviewed Date: 03/25/2022 EPA reviewed DMRs submitted by Meigs County to Ohio EPA for the period of January 1, 2017, to February 28, 2022. The DMR review showed 53 exceedances of the effluent limit for Ammonia-Nitrogen. Document(s) 1. Effluent Limit Exceedances Report.pdf Photo(s) 1. RIMG2473.JPG 2. RIMG2474.JPG 3. RIMG2478.JPG 4. RIMG2481.JPG SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. Unit: Landfill AH2-RR-001 Citation: 4 of 9 Meigs County Landfill Inspection Date(s): 02/17/2022 - 02/17/2022 The DMR review showed 53 exceedances of the NPDES permitted effluent limit for Ammonia-Nitrogen. AH2-RR-003 Citation: NPDES permit OH0135038 Part I, A. Part I, C. of the NPDES permit contains a Schedule of Compliance that requires the Facility to submit a plan to Ohio EPA that details any necessary construction or process changes to the treatment process to achieve compliance with the final effluent limits for ammonia. The compliance schedule requires the Facility to implement the specific plan within 12 months of the effective date of the permit. At the time of the inspection, the Facility had not submitted nor implemented the plan. Citations Part I, C. NPDES permit OH0135038 AH2-OB-001 The AgriDrain water level control structure at the start of Cell One was flooded at the time of the inspection and there was water pooling around it. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Region 5 Lead inspector held a closing conference with Facility personnel at 10:30 AM (ET) on 02/17/2022 for the inspection. During the closing conference, Region 5 Lead inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. EPA conducted the closing conference at the Meigs County Highway Department. EPA discussed the areas of concern with Mr. Triplett, specifically the ammonia effluent limit violations and the submission and implementation of a plan to comply with the ammonia effluent limits. Mr. Triplett informed EPA that the inspection report should be addressed to the Meigs County Commissioners. 5 of 9 Meigs County Landfill Inspection Date(s): SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log APPENDIX 1: PHOTOLOG Discharge from Cell Two of the treatment wetland RIMG2473.JPG 02/17/2022 08:50 AM (ET) Andi Hodaj Landfill No CBI No PII Discharge from Cell Two of the treatment wetland. This is where the facility takes the samples required by the NPDES permit. Camera looking East. Discharge to tributary of Thomas Fork RIMG2474.JPG 02/17/2022 08:51 AM (ET) Andi Hodaj Landfill No CBI No PII Pipe discharging to the tributary of Thomas Fork. Camera looking West. 02/17/2022 - 02/17/2022 6 of 9 Meigs County Landfill Inspection Date(s): Wetland Cell One RIMG2478.JPG 02/17/2022 09:07 AM (ET) Andi Hodaj Landfill No CBI No PII Wetland Cell One had some vegetation in it. The discharge from Cell One to Cell Two was controlled by an AgriDrain structure. Camera looking East. Capped landfill RIMG2481.JPG 02/17/2022 09:18 AM (ET) Andi Hodaj Landfill No CBI No PII Capped landfill area. Camera looking South. Wetland Cell Two RIMG2475.JPG 02/17/2022 08:53 AM (ET) Andi Hodaj Landfill No CBI No PII Cell Two of the wetland. Camera looking East. 02/17/2022 - 02/17/2022 7 of 9 Meigs County Landfill Inspection Date(s): BioDiffuser RIMG2476.JPG 02/17/2022 08:58 AM (ET) Andi Hodaj Landfill No CBI No PII Bubbling on the surface of Cell Two where the BioDiffuser was installed. EPA also observed an oil sheen on the pooling water at Cell Two. Camera looking down. Oil sheen RIMG2477.JPG 02/17/2022 08:59 AM (ET) Andi Hodaj Landfill No CBI No PII EPA also observed an oil sheen on the pooling water at Cell Two. Camera looking down. Wetland Cell One RIMG2479.JPG 02/17/2022 09:08 AM (ET) Andi Hodaj Landfill No CBI No PII Water pooling and vegetation are visible in Cell One. Camera looking West. 02/17/2022 - 02/17/2022 8 of 9 Meigs County Landfill Inspection Date(s): Flooded water level control structure RIMG2480.JPG 02/17/2022 09:11 AM (ET) Andi Hodaj Landfill No CBI No PII The AgriDrain water level control structure where the landfill leachate enters the wetland, was flooded at the time of the inspection. Camera looking South. Wetlands Cell One and Two RIMG2482.JPG 02/17/2022 09:25 AM (ET) Andi Hodaj Landfill No CBI No PII View of the wetland from the landfill area. Camera looking west. 02/17/2022 - 02/17/2022 APPENDIX 2: DOCUMENT LOG Document Type DMR Reports Document Name Contains CBI Effluent Limit No Exceedances Report.pdf Contains PII No Uploaded By Andi Hodaj Date Received 03/28/2022 9 of 9 Effluent Limit Exceedances Report OH0135038: MEIGS CO LANDFILL, POMEROY, OH 45769 Monitoring Period Date Range: 01/01/2017 to 02/28/2022 Exceedance Details Monitoring Outfal Parameter Period Date l Description 2/28/2017 1 2/28/2017 1 3/31/2017 1 3/31/2017 1 3/31/2017 1 4/30/2017 1 4/30/2017 1 5/31/2017 1 5/31/2017 1 7/31/2017 1 12/31/2017 1 12/31/2017 1 3/31/2018 1 3/31/2018 1 4/30/2018 1 4/30/2018 1 5/31/2018 1 5/31/2018 1 Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Oil and grease, hexane extr method Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Oil and grease, hexane extr method Nitrogen, ammonia total (as N) Limit Type MO AVG DMR Value (mg/L) 14.2 Limit Value (mg/L) 13 % Exceedance 9 DAILY 14.2 13 9 MX DAILY 11 10 10 MX MO AVG 35.9 13 176 DAILY 35.9 13 176 MX DAILY 23.2 13 78 MX MO AVG 23.2 13 78 MO AVG 23.8 1.6 1388 DAILY 23.8 13 83 MX MO AVG 6.83 1.6 327 MO AVG 20.8 13 60 DAILY 20.8 13 60 MX DAILY 51.8 13 298 MX MO AVG 51.8 13 298 DAILY 20.9 13 61 MX MO AVG 20.9 13 61 DAILY 24.6 10 146 MX MO AVG 3.32 1.6 108 9/30/2018 1 10/31/2018 1 11/30/2018 1 12/31/2018 1 12/31/2018 1 1/31/2019 1 1/31/2019 1 2/28/2019 1 2/28/2019 1 3/31/2019 1 3/31/2019 1 5/31/2019 1 6/30/2019 1 2/29/2020 1 2/29/2020 1 5/31/2020 1 5/31/2020 1 6/30/2020 1 6/30/2020 1 2/28/2021 1 2/28/2021 1 3/31/2021 1 3/31/2021 1 Nitrogen, ammonia MO AVG 2.4 1.6 50 total (as N) Nitrogen, ammonia MO AVG 10.6 1.6 563 total (as N) pH DAILY 6.48 6.5 MN Nitrogen, ammonia MO AVG 15.2 13 17 total (as N) Nitrogen, ammonia DAILY 15.2 13 17 total (as N) MX Nitrogen, ammonia DAILY 16 13 23 total (as N) MX Nitrogen, ammonia MO AVG 16 13 23 total (as N) Nitrogen, ammonia MO AVG 15.1 13 16 total (as N) Nitrogen, ammonia DAILY 15.1 13 16 total (as N) MX Nitrogen, ammonia MO AVG 17.6 13 35 total (as N) Nitrogen, ammonia DAILY 17.6 13 35 total (as N) MX Nitrogen, ammonia MO AVG 12.2 1.6 663 total (as N) Nitrogen, ammonia MO AVG 2.88 1.6 80 total (as N) Nitrogen, ammonia MO AVG 14.6 13 12 total (as N) Nitrogen, ammonia DAILY 14.6 13 12 total (as N) MX Nitrogen, ammonia DAILY 15.5 13 19 total (as N) MX Nitrogen, ammonia MO AVG 15.5 1.6 869 total (as N) Nitrogen, ammonia MO AVG 20.7 1.6 1194 total (as N) Nitrogen, ammonia DAILY 20.7 13 59 total (as N) MX Nitrogen, ammonia MO AVG 14.7 13 13 total (as N) Nitrogen, ammonia DAILY 14.7 13 13 total (as N) MX Nitrogen, ammonia MO AVG 19.1 13 47 total (as N) Nitrogen, ammonia DAILY 19.1 13 47 total (as N) MX 4/30/2021 1 4/30/2021 1 5/31/2021 1 5/31/2021 1 6/30/2021 1 8/31/2021 1 9/30/2021 1 12/31/2021 1 12/31/2021 1 1/31/2022 1 1/31/2022 1 2/28/2022 1 2/28/2022 1 Nitrogen, ammonia MO AVG 22.3 13 72 total (as N) Nitrogen, ammonia DAILY 22.3 13 72 total (as N) MX Nitrogen, ammonia DAILY 17.4 13 34 total (as N) MX Nitrogen, ammonia MO AVG 17.4 1.6 988 total (as N) Nitrogen, ammonia MO AVG 9.35 1.6 484 total (as N) Nitrogen, ammonia MO AVG 6.47 1.6 304 total (as N) Nitrogen, ammonia MO AVG 8.1 1.6 406 total (as N) Nitrogen, ammonia DAILY 21.3 13 64 total (as N) MX Nitrogen, ammonia MO AVG 21.3 13 64 total (as N) Nitrogen, ammonia DAILY 25.3 13 95 total (as N) MX Nitrogen, ammonia MO AVG 25.3 13 95 total (as N) Nitrogen, ammonia DAILY 17.3 13 33 total (as N) MX Nitrogen, ammonia MO AVG 17.3 13 33 total (as N)