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02-15-2000 - BKK Landfill Closure Plans Status Reportcity of Wat coz�= Memprandum AGENDA TO: City Manager and City Council ITEM NO.- 0-5c lary 15. 2000 DATE Febru FROM:. Steven L. Samaniego, 11 (9 PRINTED ON RECYCLED PAPER Environmental Management Director SUBJECT:-. BKK Landfill Closure Plans Status Report SUMMARY: This is an updated report on the STATUS OF PLANS FOR BKK LANDFILL CLOSURE and other related BKK matters. BACKGROUND: The latest edition of the STATUS OF PLANS FOR BKK LANDFILL CLOSURE is attached. This is apart of the City Community Outreach Program to keep the co mmunity informed of the progress toward implementation of the closure plans for the bKK Landfill. Staff recommends the City Council receive and file this report. 11�1 .The following is a list summarizing the BKK Landfill Closure Activities Progress for the last 30 days. Any changes made from last month's report will be in.bold. 1. Grading Plans. 2. Landscaping of Class III Landfill .3. Landscaping of the Class I Landfill 4. Landscaping to Screen the Class I Landfill. 5. Azusa Frontage Screening 6. Dust Control Plan 7. Class III Landfill Final Closure and Postclosure Plan 8. Class I Landfill Postelosure Plan RECOMMENDATION: It isrecommended that the City Council receive and file this report. Steven L. Samaniego, R.E.H.S. Environmental Management, Director Attachments Status of Plans for BKK Landfill Closure Exhibit 1, BKK Settlement Agreement, Page I Exhibit II, BKK Settlement Agreement, Attachment B, Grading 1� bkk/stat4 1. PRINTED ON RECYCLED PAPER SLS 2/8/00 STATUS OOPL,kNS, FOR BKK LAND]*L CLOSURE as of February 10, 2000 GRADING PLAN Grading of the southwest ridge and grading of the, west ridge (along Azusa Avenue) has stopped until the City certifie's the EIR and LEA approves the complete site Final Closure Plan. The westerly ridgelines highest elevation point prior to grading was Approximately 675 feet. Since the, grading, the current elevation as of Wednesday, October 13, 1999 was approximately 650 feet. Therefore, BKK has graded approximately 25 feet of the hillside. 7he 1996 Settlement Agreement between BKK and the City of West Covina specified that BKK will not grade the outward facing slopes of the north ridge lines (attached Exhibit 1). BKK is now proposing to do some grading of the north ridgeline along the northerly edge of the BKK property. The grading proposed is a result of the golf course development. In order to facilitate the development of the golf course, BKK has requested that the City approve an amendment to the Settlement Agreement to modify the condition regarding the north ridgeline. This item will also be discussed at a future City Council meeting. 2. LANDSCAPING OF CLASS III LANDFILL The landscape work has been divided into five major phases, termed Phases A through E (see Map, Page_4). Phase A landscape work was completed in July 1998. Phase B was completed in mid -August 1999 and, Phase" C was scheduled to be - completed by Dedember 1999, w*hich has been extended'to. the end of May 2000. On December 2, 1999 BKK was requested to submit in writing, an updated schedule confirming the completion date of the partial final closure with the remaining tasks. Attached is a copy of BKK's letter dated January 12, 2000 providing an updated schedule.with an explanation on the delay. In summary, the delay'was primarily due to unresolved performance issues with their landscape contractor. BKK's proposed schedule of completion is now tentatively by the end of May 2000. Because the completed.Phase A results showed that not all of the seed types had germinated, BKK proposed in Phase B to remove the unsuccessU seeds and replace them with an additional-15 containerized trees and shrubs per acre. �The City approved the proposal in June 1999 and BKK began planting qontainerized plants that. same month. The planting is being followed by hydroseeding,' Which is completed. BKK has re-hydroseeded the random bare areas in Phase A concurrent with the Phase-B hydroseeding effort, but no new growth has been noted. Because of concerns regarding weeding in'Phase A, BKK prepared Phase" B slopes with a herbicide before planting. . The. herbicide is expected to help reduce the level of effort for weeding the planted slopes. The weeds in Phase B are very Abundant with little evidence of hydroseed germination. BKK is currently weeding the slopes. Many of the weeds have flowered. The Bermuda grass weed has been spreading without any weed control management by BKK. BKK was placed on notice December 29, 1999 to begin control of the Bermuda grass. 3. LANDSCAPING OF THE CLASS I LANDFILL BKKSTATUS41 SLS 2/10/00 Note: Class'I = closed hazardous waste landfill. Class III = closed household waste landfill. DTSC = California Department of Toxic Substances Control USEPA.= United States- Environmental Protection Agency CIWMB California Integrated Waste Management Board I 7 STATUS 010PL-ANS FOR BKK LANDALL CLOSURE as of February 10, 2000 BKK submitted a revised landscape. enhancement plan in, May 1997, Tfter which the City provided comine I nts in June 1998. BKK then submitted' its response in September 1998 coupled with. a, request to convene a'meeting to finalize the plan, which is pending the City's response. A side issue that has arisen is BKK's January 1998 request to RWQCB to revise and increase, the permit limits for the qua lity of mixed irrigation water that has been used since., 1987 on the closed Class I landfill. This water is a combination of city water and smaller amounts of reclaimed site water. While not planning to alter the watermix on -site, BKK had asked to change the permit with increased salt levels -so that the -permit matches true background groundwater condition. The City is opposed to the' increase in salts due to the potential detrimental impacts salts have on. plants, especially when the mixed water will be used for irrigation of the proposed new landscaping. BKK submitted a proposed resolution to the City in August 1998, which is. pending the City's response. The City and BKK have yet to meet and agree on the landscape plan, I including the resolution of the. irrigation water quality. Upon agreementiof I a landscape plan, the City and BKK will jointly submit the plan to DTSC for approval. 4. LANDSCAPING TO.SCREEN THE CLASS I. LANDFILL In 1997 and .1 998,7BKK. installed a perimeter screen of trees along the south and southeast border of the closed Class I landfill. Because of a potential conflict with a new road that may be built to accommodate futdre site development, a portion of the screen (along the southern border) has been temporarily installed with boxed trees instead of permanently plant ed in the ground. The plan is for the boxed trees to be planted in the ground once the road alignment. is resolved. This ternporary screening may require a modification to the Settlement Agreement.. In May 1999 the City Council approved a 'one-year extension to the approval to keep a portion of the trees in temporary boxes. That extension runs until June 2000. The boxed trees must be planted within 60 days �'of resolving this issue. 5. AZUSA FRONTAGE SCREENING If BKK proposes to excavate the Westerly ridgeline below the trigger elevation level so that it no longer blocks the view from passing cars, BKK will be required to install a tree screen along Azusa Avenue. BKK has not yet made the noted grading proposal, so the tree screen issue is currently moot. Whenever it is proposed, a potential conflict with underground City utilities will have to be resolved which may require a modification to the Settlement Agreement. 6. DUST CONTROL PLAN, There is a requirement to implement a dust control plan for the future graded pads at the proposed business park. The plans are pending City,i' s approval. The plan would remain in force until development covered the building pads. This requirement does not apply until BKK grades the westerly and southwest ridges . down to the proposed business park BKKSTATUS41 Note: Class I = closed -hazardous I Waste landfill. SLS, Class III = closed household waste landfill. 2/10/00 DTSC California Department of Toxic Substances Control �USEPA United States Environmental Protection Agency. CIWMB; California Integrated Waste Management Board 2 STATUS O*LANS FOR BKK LANDFOL C-LOSURE as of February 10, 2000 elevations, which has not yet occurred. BKK submitted a plan to the City in 1996 for review and approval. T. CLASS III LANDFILL FINAL CLOSURE AND POSTCLOSURE PLAN The first three of the five major construction phases (A, B, C, D and E) have been -proceeding under the approved Partial Final Closure Plan. The complete site Final Closure Plancovers the remaining two construction phases D and E, (see attached map). The� draft Environmental Impact Report and Health Risk Assessment has been released for public review. The comment period ended October 7, 1999. Certification of the final EIR by the City Council is expected in March 2000. Closure work for Phase A and Bis complete. Phase C final soil cover placement work has been completed."Th . e Phase C landfill gas control system has been installed. Phase C closure work and landscaping was scheduled to be completed by December 1999. On December 2, 1999 BKK was asked to submit, in writing, an updated schedule confirming the completion date of the partial . final closure with the remaining tasks. At ' tache'd is a copy of BKK's response letter dated January 12, 2000.' In summary, the delay was primarily,due to unresolved performance issues with their contractor. BKK's proposed schedule of completion is now tentatively by the end of May 2000. The final cover soil is comprised of a 7.5-foot vegetative soil layer on top of the one -foot clay cap barrier layer and.two-foot of foundation soil layer. This greatly exceeds regulatory requirements and was done, as part of the MOU litigation settlement, in order to have more than adequate thickness to accommodate the. deeper roots of trees.- The 1996 Landfill Settlement Agreement between BKK and the City of West Covina specified that the final cover/vegetative layer shall consist of a seven and one-half (7.5) foot deep vegetative soil layer (attached Exhibit 11). In July 1997 the City informally approved a reduction in the' vegetative soil layer thickness to three feet in areas such as bench roads that have no vegetation (and therefore do not need the thicker layer). Thig informal administrative approval may require modificdtion to the Settlement Agreement. BKK is also proposing to extend the variance of: less' than 7.5-foot vegetative final cover soil onto the top deck of the Class III. The proposed golf course on the top deck is planned to have areas with less .than 7.5-foot vegetative soil where trees will not be planted. BKK has proposed this in the complete site final closure plan. 8. CLASS I LANDFILL POSTCLOSURE PLAN The closed Class I Lan ' dfill has been operating since 1989 in accordance with DTSC postclosure regulations, but without the. site -specific postclosure p ' ermit. DTSC has announced that the postclosure permit public comment period will be for 90 days commencing November 15, 1999 through February 15, 2000. Also, there was a public hearing on the postclosure permit on December 15, 1999 at the City Hall Community Room at 7:00 p.m. - The draft permit is available for public review at the West Covina Public Library, the City's Environmental Management Department and City of Walnut Public Library. BKKSTATUS41 Note: Class I = closed hazardous waste landfill. 3 SLS Class III closed household waste landfill. 2/10/00 DTSC California Department of Toxic Substances Control USEPA United States Environmental Protection Agency CIW.MB California Integrated Waste Management Board STATUS OWLANS FOR BK'K LAND4L CLOSURE as of February 10, 2000 DTSC held a community meeting in the City Council Chambers on January 24, .2000 for the Draft Postclosure Permit. Representatives from DTSC, Water Quality, U.S. EPA, C1WMB and Air Quality were available to respond to any questions or comments from the public. City comments were sent to DTS C on February 10, 2000. The next step in the process is for DTSC to respond to, all comments and take action on the permit. BKKSTATUS41 Note: Class I closed hazardous waste landfill. SLS Class III = closed household waste landfill. 2/10/00 DTSC California Department of Toxic Substances Control USEPA United States Environmental Protection Agency CIWMB California Integ ted Waste Management Board gra El 4 EXHIBIT I This agreement is to memorialize the understanding reached by BKK Corporation CSKIC') and the City6f West Covina C'City'� (collectively the "Parties") regarding Settlement of the dispute involving grading activities on the landfill site which BKK on the one hand contends it has the rights to conduct, and which the City, on the other hand contends BKK does not have the right to conduct. In part, by letter agreement executea February 23, 1993, theyarties had placed on hold resolution Of the disputes addressed by that letter agreement and the matters addressed herein., The parties h ave now determined to resolve some of their outstanding. disputes concerning the matters addressed herein according to the following terms and conditions: 1. BKK shall conduct mitigation activities as described in attachments "A" and "B" attached hereto and by this'reference incorporated herein. 2. City agrees to allow BKK to conduct the mitigation activities including grading to complete disposal operations and to facilitate closure of the landfill.site described in attachments "A" and "B" attached hereto. 3. City agrees'the mitigation'activities described in attachments "All and "B" hereto are not subject to the terms of CEQA or the UUP, including environmental review under CEQA. 4. BKKAgrees that its final closure plan will be subject to environmental review under CEQA. S. BKK Agrees *that any grading of the Northwest Ridgeline, as shown on attachments 1W. I and "B" shall be in conjunction with the filling of the North Stepout area and subsequent development of the site for recreational or other permitted purposesl and shall be subject to review and approval by the City, after environmental review under CEQA. BKK agrees to maintain the existing outward facing slopes of the North Ridgeline area, by not altering, grading or removing soil from the existing natural outward facing slopes. 6. This agreement amends by superseding, the aforementioned February 23, 1993, letter agreement. E EXHIBIT H GRADING BKK has the right to grade the areas described on the -attached Conceptual Grading Plan, in the following phases. Phase I shall consist of grading in Areas I and 2 for daily cover within the Class III Landfill or for placement within Areas A and B for the purposes of final cover or a vegetative layer. Phase shall consist of grading in Areas I and 2 for daily cover within the Class III Landfill or for placement, in Area C f6r the purp oses: of final cover or a vegetative layer. Phase III shall consist.of grading in Areas I and 2 &r daily cover within the Class'III Landfill or placement in Area D for the purposes of final cover or a vegetative layer. Phase IV shall consist of grading in Areas I and 2 for daily cover within the Class, III Landfill or for placement, in Area E for the purposes of final cover or a vegetative layer. Phase V of the grading will be in the 9 Northwest Ridgeline area of the Landfill and will be subject to the limitations expressed in paragraph 5 of the attached Agreement. The above -described phases may proceed' concurrently if, in the sole- business judgment of BKK and after notification to the City Planning Department, the efficient operation of the Landfill and final grading so requires. The final cover/vegetative layer shall consist of a seven and one-half (7.5) foot deep vegetative soil layer, a one foot deep barrier layer and a two foot deep foundation layer. Prior to, grading of any ridgeline or outward facing slopes within Areas 1 or 2, BKK shall submit detailed soil quantity calculations for phases I through IV to demonstrate that adequate goil.exists for daily cover and final cover/vegetative layer and a rough grading plan for phases I through IV showing final pad elevatiom and design -for