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LEA Advisory 20 Attachment- Inspection Guidance for SW Landfills Page 5 of 52 Arriving at the Facility In order to detect unpermitted operations and verify facility operating hours, application of daily cover, and security precautions, the inspector should arrive at the facility before it opens in the morning. This is not possible at all facilities, i.e., those with continuous operations. In those cases, the inspector should evaluate the cover standard at the time cover is required to be deposited in accordance with the RDSI or SWFP. Gaining Access When entering a facility for the first time, the inspector should drive first to the gatehouse via the same entry point used by the public and/or contract waste haulers. At the gatehouse, the inspector should state the following: name, employer, reason for site visit, and that photos may be taken as documentation. The employee at the gatehouse will either tell the inspector to go on with the inspection or direct the inspector to speak with an official at the facility. If no employee is present at the gatehouse, or there is no gatehouse or scalehouse, the inspector should attempt to find an employee at the site by going to the office area, maintenance area or the working face. Upon finding an employee, the inspector should follow the introduction described above. Denial of Access If access is denied in any way, the inspector should politely determine if the individual denying access is the appropriate official to make such a decision. The inspector should ask the reason for denial of access and verify that the purpose and authority to conduct the inspection under the PRC are understood. If access is still denied, the inspector should abide by the operator's wishes, document the name of the person denying access, and then call his/her agency's supervisor. The supervisor, working with the appropriate county, state, or Cal/EPA legal staff, should pursue the steps necessary to gain access, using an inspection warrant. In addition to outright denial of entry, access denial may include preventing the inspector from bringing in necessary equipment(camera),preventing access to documents, or denying entry if the inspector refuses to sign a waiver or other legal document(s) restricting the owner/operator's liabilities or obligations. The reception of the inspector and the helpfulness of SWT officials will vary from site to site. Most inspections can be accomplished without adversarial confrontations. However, inspectors may be threatened by facility representatives during an inspection. If threatened with violence,the inspector should immediately stop the inspection, leave the site or area where the threat exists, and contact his/her supervisor as soon as possible. The name of the person who has threatened violence and nature of the threat should be noted in the inspection report. Health and Safety Considerations Board staff recommend that each jurisdiction develop a health and safety plan for conducting inspections of solid waste facilities. The plan should include equipment requirements for field staff. For reference, the Board's Interim Field Health and Safety Plan requires Board inspectors to wear overalls, hard hat, safety vest, safety glasses and safety boots during an inspection. Ear protection and a dust mask should also be immediately available. See Appendix A for recommended health and http://www.ciwmb.ca.gov/pe/advisory/20/attach20/20attch 1.htm 8/11/98