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tate Inspection- Furnace Gk Disposal Site • Page 5 of 6 Facility No.- 14-AA-0016 comments: Violations 30 PRC 44014(b) Permit, Terms and Conditions- Board staff observed the following violations of the terms and conditions of the site's SWFP: 1. The SWFP states under 11 of Findings, "There is no salvaging operation occurring at the site." At the time of the inspection, four "salvaged" trailers were being stored on the site's lower fill area, twenty yards west of the "dry wood" and "green wood" signed tipping area. 2. The 12/78 SWFP specifically prohibits the burning of waste under #1 of Prohibitions. An ash/dirt pile (10 yards in diameter and 6 feet high) was observed fifteen yards east of the "salvaged/stored" trailers, adjacent to and contiguous with the "dry wood" tipping area. Many metal items (cans and wire) were dispersed among the ashes. The operator indicated that prior approval for this practice had not been sought from or granted by the LEA, Board, or Great Basin Air Pollution Control District. (Note: Please be aware that on 10/9/91 the U.S. Environmenta ` _ N � Protection Agency (EPA) finalized Subtitle D Criteria of the revised Federal Gesource Conservation and Recovery Act (RCRA) . The finalized Subtitle D Criteria . 5 pheld the ban on open burning of solid wastes originally established in 1979 in he part 257 Criteria. Pursuant to Part 257 of Subtitle D, Section 258.24(a) equires owners/operators of landfill units to comply with applicable requirements f State Implementation Plans (SIPS) developed under section 110 of the Clean Ai . ct (CAA) and 258.24(b) prohibits the open burning of solid waste, except in' limited circumstances, at all solid waste landfills units. The Great Basin Unified �i Air Pollution 12ontrol District (619-872-8211) should AIMFonsulted for further. A/}gj d clarification MOM matter. ) 3� 3. The 12/78 SWFP, under #3 of the Self Monitoring Program section, requires the '� operator to maintain and update quarterly ". . .a map record showing the exact - location of any subsurface cuts where fill has been placed, cover material mined, or where area fill has been placed on natural soil." On the day of the inspection, such a map record was not available for review on-site or at the operator's office. 14 CCR 18213(b) 5-Year Permit Review- Board records indicate that a 5-Year Permit Review for this facility has not occurred since the 12/14/78 issuance of the SWFP. Board correspondence of 5/16/88 informed the operator ". . .that the permit issued to the above facility (Furnace Creek, 14-AA-0016) is in need of review." This correspondence continued, ". . .an application for permit review, including an updated Report of Disposal Site Information and an engineering review (Periodic Site Review] should be filed with the local enforcement agency by October 1, 1988. Upon completion of its review, the local enforcement agency will determine if a revision of the permit is required." As of the date of the inspection, an application for a permit review along with other specified documents has not been submitted to the LEA. 14 CCR 17607 Periodic Site Review- The PSR is a process that provides assurance to both the LEA and the Board that a facility operator receives recommendations from a registered civil engineer that enhance site conditions based on conclusions developed during an engineering review. As noted under 14 CCR 18213(b) above, Board correspondence of 5/16/88 regarding the 5-Year Permit Review informed the operator that a PSR is ". . .required at least every five years and should be completed and submitted with the application for permit review to your local enforcement agency." Such a submittal has not been received as of this date. 14 CCR 17616 Report of Disposal Site Information- Board records indicate that this facility's most recent RDSI is dated 8/15/78. As noted under 14 CCR 18213(b) above, Board correspondence of 5/16/88 regarding the 5-Year Permit Review informed the operator that ". . .an updated Report of Disposal Site Information. . .should be filed with the local enforcement agency by October 1, 1988." The RDSI must reflect all current operations at the site and thoroughly and completely address each section, a-1, of 14 CCR 18222. An updated RDSI has not been filed with the LEA or Board as of this date. Waste Management Speciali