Republic Services of Michigan I, LLC, doing business as Carleton Farms Landfill, Wayne County, Michigan On June 22, 2007, the Michigan Department of Environmental Quality (DEQ) entered into an Administrative Order (Order) with Republic Services of Michigan I, LLC, doing business as Carleton Farms Landfill (Carleton Farms) in Wayne County, to resolve alleged violations of Part 115, Solid Waste Management, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended. The alleged violations were based on results from the occurrence of a major waste mass movement on the west slope area of Cell 211 of the Carleton Farms Landfill in July 2006. The violations that resulted from the waste mass movement include: allowing solid waste to be disposed of outside of the area authorized by the license, failure to maintain adequate daily and interim cover, and failure to ensure that the leachate depth on the liner is not more than one foot. It is believed that the movement of the waste mass into an unlicensed area occurred because of the amount of waste water treatment plant sludge historically disposed of in Cell 211 and the methods used for its placement. The recirculation of leachate may also have contributed to the instability that resulted in the waste movement. As part of the movement of the waste, waste water treatment plant sludge and leachate flowed outside of Cell 211. In addition, erosion gullies and large cracks in the interim and daily cover developed exposing waste, allowing odors to escape, and resulting in the infiltration of storm water into the waste. Shortly after the mass movement of the waste occurred at the landfill, Carleton Farms suspended leachate recirculation and waste placement in Cell 211 and constructed a large clay buttress to stop the movement of the waste mass. Studies have been undertaken by Carleton Farms to determine whether the movement of the waste has been halted by the corrective actions taken to date and whether there has been damage to the liner and leachate collection systems by the movement of the waste mass. A previous consent order entered on June 6, 2006 (2006 Consent Order), is in place to address odor issues at Carleton Farms that were exacerbated by the acceptance of the waste water treatment plant sludge. Under the 2006 Consent Order, Republic agreed to cease accepting waste water treatment plant sludge as of August 1, 2006, which they did. WHMD and Wayne County Department of Environment (WCDOE) staff believe the revisions to the gas collection system required by the 2006 Consent Order will address the gas odor issues that have resulted from the waste movement. To address the other violations, the Order provides for the revocation of the authority to recirculate leachate under the existing leachate recirculation plan, except for the limited use of leachate to control fugitive dust emissions at the active area of the landfill. Future leachate recirculation would need to be authorized under a new plan. Carleton Farms will need to provide a verification of soil cleanup report documenting the remedial activities to address the impacts resulting from the migration of waste water treatment plant sludge and leachate outside of Cell 211. Carleton Farms will also need to provide the following to the WHMD and WCDOE: a plan to address the drainage of leachate from the landfill cells adjacent to Cell 211; an evaluation and demonstration that stability will be maintained as part of any future application to reinstate the acceptance of waste water treatment plant sludge at the landfill; a monitoring plan to investigate the moisture content and evaluate the stability of the waste mass; a report on the inspection of the condition of leachate collection pipe in Cell 211 via television; and verification that the leachate head on the liner is not more than one foot. They will also need to provide a record of the volumes of leachate removed, monitor the effectiveness of the dewatering activities, inspect the interim cover, prevent the infiltration of storm water into the waste mass, minimize landfill gas emissions, and evaluate the impact of the waste outside of Cell 211. As part of the requirements of the Order, Carleton Farms must also provide a corrective action plan for the west slope area of Cell 211, including plans to address additional dewatering, removal of the stabilizing buttress, if proposed, and contingencies for any instability encountered. This plan must also provide for the removal of the waste outside of the cell or an adequate demonstration that the risks posed by leaving the waste in place have been addressed, placement of a liner over the waste mass in Cell 211 and other areas draining leachate to Cell 211, and submittal of a final report on the corrective actions. As part of the Order, Carleton Farms will pay to the State of Michigan $94,000 in fines and $5,500 in costs for surveillance and enforcement activities undertaken by the DEQ.
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