National Environment and Planning Agency

Enforcement Branch National Environment and Planning Agency Post Suspension Notice Monitoring Report

Inspection Date: 27 January 2017 Report in series # 1 of 2017

Time of Inspection: 10:40 a.m.

Location: Riverton, St Andrew

Person in Breach: National Solid Waste Management Authority

Present were: Keisha Pennant and Marva Smith-Moodie (NEPA) Calvert McLeod - Landfill Manager (NSWMA) and Larel Thomas-supervisor (NSWMA)

Notice Served on: National Solid Waste Management Authority

Effective date: 28 April 2015

Served by: Clive Rochester- Enforcement Inspector, Enforcement Branch (NEPA)

Notice Received by: A. Mais– (NSMWA)

Appeal to and date: None

Background

Nature of Contravention

Part A - Specific Offending Activity and Area Lack of adherence with enforcement instruments served for breaches to Environmental Permit with ref #: 2012-02017-EP00145 for Solid Waste Treatment and Disposal Facility at Riverton, St Andrew.

Part B - Nature of Threat

The threat to environmental and public health of improper disposal of solid waste at the disposal facility and endangerment of unauthorized/authorized persons on the landfill.

Part C - Steps to Ameliorate Effects of Activity or Restore Area

Level of Comments/Action No General Conditions compliance 1. All works carried out pursuant to this NC This condition remains non- Permit shall be performed under the compliant, there is no professional supervision of trained evidence on file to suggest or personnel who are qualified and indicate that this condition competent to carry out the functions and was met. duties of the Permitted Activity and who are conversant with the accompanying safety requirements and the hazards to workers, the public and the environment. 9. The Permittee shall, prior to the NC commencement of the permitted This condition was non- activity, post a sign in a prominent place compliant. It should be noted at the location of the permitted activity that this condition is non using the same design and words as in rectifiable. the template attached. Level of Comments/Action No Specific Conditions compliance 1. The Permittee shall comply with all NC This condition remains non representations made in the Permit complaint. There are several Application Form undated and Project things that were in the Information Form dated 7 August 2012, referred documents that are both received and date stamped 7 not yet in place. These include August 2012 by the Authority, the following: document titled “RIVERTON 1. The Leachate Pond is DISPOSAL SITE ENVIRONMENTAL not yet constructed PERMIT APPLICATION PROJECT 2. On site drainage way BRIEF” dated 14 May 2013, received leaving the tire storage and date stamped 15 May 2013 by the site Authority, document titled 3. No Air Quality report “RIVERTON CITY LANDFILL was submitted. BRIDGE STRUCTURAL ENGINEERING DESIGN” dated August 2000 received and date stamped 7 August 2012 by the Authority, document titled “Vector Control & Management Program Riverton Solid Waste Disposal Facility” dated 6 February 2013 received and date stamped 15 May 2013 by the Authority, document titled “Stormwater Drain & Leachate Pond Maintenance Plan Riverton Solid Waste Disposal Facility” dated 6 April 2013 received and date stamped 15 May 2013 by the Authority, document titled “Calculations for Leachate Generation & Pipe Sizes Riverton Solid Waste Disposal Facility” dated 20 May 2013, received and date stamped 27 May 2013 by the Authority, drawings titled “ENVIRONMENTAL PERMIT APPLICATION FOR THE RIVERTON SOLID WASTE DISPOSAL SITE” dated 30 July 2012, received and date stamped 15 May 2013 by the Authority, drawings titled “PROPOSED GAS EXTRACTION PLAN OF THE RIVERTON SOLID WASTE DISPOSAL SITE” dated 4 October 2012, received and date stamped 4 October 2012 by the Authority, and any other accompanying addenda. 8. The Permittee shall ensure that the Partial There is partial compliance as designation of active and dormant cells, the coverings of tipped solid quarterly cell rotation, as well as the waste on site as well as the areas designated for the different types designation of active and of waste are operated and maintained as dormant cells were done. described in document titled However there are still “RIVERTON DISPOSAL SITE animals present on site along ENVIRONMENTAL PERMIT with unauthorized persons. APPLICATION PROJECT BRIEF” There is still no leachate pond dated 14 May 2013, received and date in place. stamped 15 May 2013 by the Authority, document titled “RIVERTON CITY LANDFILL BRIDGE STRUCTURAL ENGINEERING DESIGN” dated August 2000 received and date stamped 7 August 2012 by the Authority, document titled “Vector Control & Management Program Riverton Solid Waste Disposal Facility” dated 6 February 2013 received and date stamped 15 May 2013 by the Authority, document titled “Stormwater Drain & Leachate Pond Maintenance Plan Riverton Solid Waste Disposal Facility” dated 6 April 2013 received and date stamped 15 May 2013 by the Authority, document titled “Calculations for Leachate Generation & Pipe Sizes Riverton Solid Waste Disposal Facility” dated 20 May 2013, received and date stamped 27 May 2013 by the Authority, drawings titled “ENVIRONMENTAL PERMIT APPLICATION FOR THE RIVERTON SOLID WASTE DISPOSAL SITE” dated 30 July 2012, received and date stamped 15 May 2013 by the Authority, drawings titled “PROPOSED GAS EXTRACTION PLAN OF THE RIVERTON SOLID WASTE DISPOSAL SITE” dated 4 October 2012, received and date stamped 4 October 2012 by the Authority, and any other accompanying addenda. Disposal of solid waste at any one time shall only be done in the designated active cell. 12. The Permittee shall submit to the NC To date no information as it Agency information on cover material regards cover material was on a monthly basis. This information submitted to the agency. shall include but is not limited to: i. Source of cover material, including location where it was taken from ii. quantity per load including quantity collected at the source and quantity received at the facility iii. mode of transport to the facility 15. The Permittee shall notify in writing the NC Condition not met cell 3A “Manager, Enforcement Branch, was activated and the Agency National Environment and Planning was not notified of such Agency, 10 Caledonia Avenue, activity. Kingston 5 or by email [email protected] the planned activation of a dormant cell at least two (2) weeks prior to the activation of the dormant cell 19. The Permittee shall during the Partial Some amount of dusting was construction and operation phase of the observed at the facility. entire disposal facility, wet road However, there was evidence surfaces and stockpiles of soil and marl that some amount of wetting to prevent the generation of fugitive activity had taken place. dust. 20. The Permittee shall enforce speed limit FULL At the time of the inspection restrictions of 15km/h throughout the the trucks that were observed disposal facility, to minimize the were thought to be within the generation of fugitive dust required speed limit. 21. The Permittee shall ensure that used Partial The tyres that were observed tyres received at the facility are baled, at the facility were not baled stacked, stored and separated into baled and they were not stacked as tyre piles. The tyre piles shall be a stipulated. However they were maximum of 6m in height, with a stacked to allow for maximum perimeter of 76m by 6m. The maneuverability around each edges of the tyre piles shall be at least tyre cell. It was indicated by 15m from the boundaries of the tyre the Land Fill Manager that cell, with that area clear of debris and tyres will be relocated to a vegetation to ensure manoeuvrability Facility in Hill Run for which around the tyre piles. A firebreak shall an application for an be maintained between the tyre piles of Environmental Permit was at least 15m to ensure access for granted. emergency response and aid with the prevention of spreading of fires. 23. The Permittee shall ensure that the solid Partial While measures such as waste disposal facility is secured to fencing, drop bar and security prevent access to the disposal site by guards were onsite; as well as unauthorized persons and animals receipts are collected from truck operators as proof that they were granted permission to enter the facility there were still animals and unauthorized persons observed at the facility. 24. The Permittee shall create and maintain NC There is some uncertainty as a buffer zone between the disposal cells to the property boundary the and the property boundary of at least 50 active cell was being operated metres of which the 15 metres closest to without a buffer zone. the property boundary must be reserved for natural or landscaped screening (berms or vegetative screens). There shall be no disposal of waste within the buffer zone 25. The Permittee shall submit a Landscape NC This condition was amended Plan to the Agency within six (6) from thirty (30) days to six (6) months of the date of issue of this months. Therefore has permit. become due since the 9 October 2014. The submission of the Landscape Plan is still outstanding. 27. The Permittee shall comply with all Partial representations made in document titled The Vector Control & “Vector Control & Management Management Program speaks Program Riverton Solid Waste Disposal to security, vector control, Facility” dated 6 February 2013, vermin control, bird control, received and date stamped 15 May 2013 fly control and the use of PPE. While some aspects, such as security on site and the use of PPE were observed, some of the measures to be taken as outlined in the document (e.g. setting of bird decoys and nets, and fencing the leachate treatment pond, control measures) were not in place. 31. The Permittee shall develop a detailed FULL Condition met, the Agency Water Quality Monitoring Plan for the was in receipt of a Water Authority’s approval and submit to the Quality Monitoring Plan. Manager, Enforcement Branch, National Environment & Planning Agency, 10 Caledonia Avenue, Kingston 5 within nine (9) months from the date of issue of this permit. The plan shall include but not be limited to:  logistics and protocols for sample collections  a list of parameters for which sampling will be conducted. This shall include pH, Specific Conductance, Total Organic Carbon, Total Organic Halogen, Iron, Lead, Sodium, Manganese, Phenols, Chloride, Sulphate, Phenols  geo-referenced data (coordinates) for the sampling points selected for ambient water quality. This shall include points upstream of the Duhaney River, prior to the river entering the disposal facility, point(s) downstream of the Duhaney River prior to the river exiting the disposal facility and the three (3) existing boreholes at the disposal facility which are to be resuscitated.  an emergency sampling plan for suspected contamination events,  geo-reference data (coordinates) for all sinkholes and relevant surface water features  test methods to be employed 32. The Permittee shall develop a detailed NC Condition remains non- Air Quality Monitoring Plan in complaint as the mention consultation with the Agency and the document was not submitted portfolio Ministers (Local Government to the agency. and Water, Land, Environment and Climate Change) within nine (9) months from the date of issue of this Permit. The Plan shall include but not be limited to the following:  An air emissions inventory for the facility  Ambient air quality Monitoring for Volatile Organic compounds that may be emitted from the facility 33. The Permittee shall ensure that burning FULL Condition met at the time of is strictly prohibited at the disposal the inspection no burning was facility taking Place. 35. The Permittee shall develop a Facility Partial A document entitled Fire Monitoring and Prevention ‘Operation Procedures for Programme for the facility with the Management of Landfill approval of Fire Department and the Fires’ was submitted to the Office of Disaster Preparedness and agency. The document was Emergency Management (ODPEM) and reviewed and it was deem not submit to the Manager, Enforcement full adequate. Branch, National Environment & Planning Agency, 10 Caledonia Avenue, Kingston 5 within three (3) months of the date of issue of this permit. The programme shall include but not be limited to the:  Daily monitoring of the facility by personnel of fire prone areas  Training of personnel in early detection and responding to fires  Training of personnel in FIRST AID and CPR  Schedule for conducting CPR training and emergency simulations  Emergency procedures protocol once an emergency is detected  Notification procedures for the relevant emergency responder based on the nature of the fire or nature of emergency with a clear protocol for the contact of relevant personnel  Reporting procedures for emergencies 38. The Permittee shall ensure that Partial Signs were observed however adequately sized signs are posted at each the signs did not bear all the entrance with the following current required information. information: 1. Site name 2. Owner and operator 3. Contact phone number and address for owner and operator 4. Phone number in case of emergency (such as fire) 5. Hours of operation (if applicable) 6. Materials/wastes accepted for disposal facility and recycling 7. Materials/wastes banned 8. Tipping fees (if applicable) Additional signs which clearly indicate the directions to the active tipping face (active cell), public disposal area, recycling and waste separation areas, Hazardous Waste Storage areas etc. shall also be displayed. 39. The Permittee shall record and maintain Partial A copy of the Permit was the following information: located at the site Office  copy of the permit(s) for the operations of the facility  inspection records for inspections conducted by staff and regulatory agencies;  training procedures;  contingency plan and notification procedures for the day to day operations of the facility  closure and post-closure care plans in regards to cell rotation activities

Observations:  Approximately 5 acres of land was left uncovered( Cell 6B and 3A)  Cell 6B was in use at the time of inspection.  Some amount of cover was applied to cell 3A  Tyres were still present at the location.  Some amount of dusting was observed (there was evidence of wetting however).  Water Hydrants were observed( it was reported that there are 12 in total)  6” gas pipes were observed (it was reported that there are 24 in total).  Cows and birds were observed onsite

In addition conversations with Mr. Thomas indicated that cell 3A was activated approximately three (3) months ago due to the fact that cell 6B was not accessible as a result of rain fall activity. He also indicated that he was in the process of covering cell 3A with waste soil that was brought to the site from development sites. It was said that no hazardous materials were received by the landfill in almost a year. He also indicated that the Local Health Department did some amount of vector control.

Technical Notes

The permit is divided in three (3) phases. Four items were to be completed in Phase 1 (1 April 2014- 31 March 2015) which included the following:  Covering of tipped solid waste onsite- this activity is being carried on a continuous. Currently there is 5 acres of land that is active.  Separation of cells and Cell rotation - the cells are separated and labelled.  Management of used tyres - there are used tyres still kept at the location however, they are packed in the shape of a pyramid.  Dust control - wetting of the site is carried out.  Air quality management (preliminary measures) - these measures are not definitive and what is to be done is not defined.  Water Quality Management (preliminary actions)- remains outstanding  Traffic Management Road Signage-this remains outstanding

Phase 2 (1 April 2015-31 March 2017)  Firefighting and Emergency response - a water storage tank has been constructed on the disposal site as well as fire hydrants have been installed on the property. Water pumps have also been installed on site.  Rehabilitation of the Duhaney River Access Bridge to the Disposal site - this has not been done.  Establishment and maintenance of a special waste cell and holding area for E- Waste – there is a container where the E – Waste is stored  Rehabilitation of sections of the access road leading to the disposal site- the road has been rehabilitated as a part of a community project.  Air Quality Management – this matter remains outstanding.  Water Quality Management - this matter remains outstanding.

Phase 3(1 April 2017- 31 March 2022)  Gas collection and flaring- this matter remains outstanding.  Construction of onsite drainage for storm water and holding ponds for leachate- this matter remains outstanding.

Conclusion Based on the site visit conducted the following can be concluded:  Of the nineteen condition that were served for three (3) were now in full compliance, eight (8) were in partial compliance while eight (8) were non complaint and  It can be concluded that while there was an increase in the compliance level there is still outstanding documentation to be submitted to the agency.

Recommendation Based on the above observations, technical notes and subsequent conclusion the following are recommended:  That the Permit remains suspended until the facility is in full compliance with the conditions of the Permit.

APPENDIX- Submitted by: Keisha Pennant Date Submitted to Supervisor: 31 January 2017 Reviewed by: C. Martin Date Reviewed: 31 January 2017 Date of Final Report: 31 January 2017