01-16-2001 - BKK Landfill Closure Plans Status ReportTO: Daniel G. Hobbs,
City Manager and City Council
FROM: Steven L. Samaniego
Environmental Management Director
SUBJECT: BKK Landfill Closure Plans
Status Report
City of West Covina
Memorandum
AGENDA
ITEM NO. C-6i
DATE January �16. 2001
® PRINTED ON RECYCLED PAPER
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 a part of the City Community Outreach Program to keep the community
informed of the progress toward implementation of the closure plans for the BKK
Landfill. Staff recommends the City Council receive and file this report.
The following is a list summarizing the BKK Landfill Closure Activities Progress forllthe ;
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 Postclosure Plan
RECOMMENDATION:
It is recommended 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
BKK Letter Dated August 25, 2000
t
bkk/statO PRINTED ON RECYCLED PAPER
SLS
01 /08/01
STATUS 010LANS FOR BKK LANDFFOLL CLOSURE
as of January 8, 2001
1.
GRADING PLAN
BKK has completed the placement of final cover soils in accordance with
the approved partial final closure plan. Since final cover soils are no
longer needed for partial closure, BKK has stopped the grading of the
southwest ridge and west ridge (along Azusa Avenue). Upon approval of
the complete site Final Closure Plan, BKK will continue the grading along
Azusa Avenue for landfill cover soils. 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.
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, B & C are part of the
partial final closure plan construction. Phase A landscape work was
completed in July 1998. Phase B was completed in mid -August 1999 and
Phase C has not been started which was scheduled for completion by the
end of May 2000. On September 6, 2000 the City Council authorized staff
to approve an amendment to Phase C Landscape Plan of the Partial final
closure Plan to be consistent with the golf course design if the golf course
is approved. Attached is BKK's proposed amendment dated August 25,
2000. Pending is City staffs letter to BKK approving the amendment
to Phase C landscape plan.
Weeding on the Class III Landfill is very slow. Weeds are allowed to get
tall, thick, flower and seed before weeding. Tall weeds hinder irrigation
coverage and inspections. The Bermuda grass weed has been spreading
without adequate weed control management by BKK. It appears that the
weeding crew is not adequately staffed to manage the weeds.
Phase A Slope C west facing in the central portion has a sparse number of
trees planted from pots. BKK has agreed to plant some additional trees on
that slope during the Phase C landscaping.
3.
LANDSCAPING OF THE CLASS I LANDFILL
BKK submitted a revised landscape enhancement plan in May 1997, after
which the City provided comments in June 1998. BKK then submitted its
response in September 1998 coupled with a request to convene a meeting
to finalize the plan.
The City and BKK have yet to meet and agree on the landscape plan,
including the resolution of the irrigation water quality. Upon agreement of
a landscape plan, the City and BKK will jointly submit the plan to DTSC
for approval. Per a meeting in December 1999, BKK has submitted to the
City on February 14, 2000, a draft joint City/BKK submittal document
seeking DTSC's clarification regarding the conditions under which the
State will allow the planting of trees on the Class I landfill. BKK is
waiting for the City's response to the draft paper.
A side issue that has arisen is BKK's January 1998 request to RWQCB to
revise and increase the permit limits for the quality 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 water mix on -site, BKK had asked
BKKSTATUS a9 Note: Class I = closed hazardous waste landfill.
SLS Class III = closed household waste landfill.
01/08/01 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
STATUS 019LANS FOR BKK LANDFO, CLOSURE
as of January 8, 2001
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.
4.
LANDSCAPING TO SCREEN THE CLASS I LANDFILL
In 1997 and 1998, BKK 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 future
site development, a portion of the screen (along the southern border) has
been temporarily installed with boxed trees instead of permanently planted
in the ground. The plan is for the boxed trees to be planted in the ground
once the road alignment is resolved. This temporary 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
ran until June 2000. In April 2000 BKK requested an additional extension.
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
not required.
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'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
elevations, which has not yet occurred. BKK submitted a plan to the City
in 1996 for review and approval.
7.
CLASS III LANDFILL FINAL CLOSURE AND POSTCLOSURE PLAN
The first three of the five major final closure construction phases (A, B, C,
D and E) have been proceeding under the approved Partial Final Closure
Plan. The complete site Final Closure Plan covers the remaining two
construction phases D and E, (see attached map).
On October 17, 2000 the City Council voted to certify the BKK Landfill
Final Environmental Impact report for the Final Closure, Postclosure and
Development. The next step BKK must do is amend the Final Closure and
Postclosure Plan to incorporate any additional changes and the EIR
mitigation measures. Upon the LEA's approval of the amended Final
Closure and Postclosure Plan BKK may commence implementation of
Final Closure for Phase D & E.
I.
BKKSTATUS 49 Note: Class I = closed hazardous waste landfill. 2
SLS Class III = closed household waste landfill.
01/08/01 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
STATUS O*LANS FOR BKK LANDAL CLOSURE
as of January 8, 2001
Per BKK Partial Final Closure construction work for Phase A and B has
not been completed for certification pending construction of the down
drain inlets. All that remains to complete Phase C is the landscaping and
construction of down drain inlets.
On July 20, 2000 the WMEQC voted to recommend that the City Council
authorize staff to approve an amendment to the Phase C Landscape Plan of
the Partial Final closure plan to be consistent with the golf course design if
the golf course is approved by the Council. On September 5, 2000 The
City Council voted in support of the WMEQC recommendation
BKK had proposed to extend the variance of less than 7.5-foot vegetative
final cover soil on the top deck of the Class III Landfill. BKK later
withdrew their proposal to reduce the 7.5-foot vegetative soil course on the
top deck per their letter dated February 15, 2000.
The Complete Site Final Closure Plan will be amended to reflect that 7.5
feet of vegetative soil cover will be placed on the top deck of the Class III
in accordance with the Settlement Agreement.
TCLOS
The closed Class I Landfill has been operating since 1989 in accordance
with DTSC postclosure regulations, but without the site -specific
postclosure permit. The postclosure permit public comment period was
from 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.
DTSC held a community meeting in the City Council Chamber_ s on
January 24, 2000 for the Draft Postclosure Permit. Representatives from
DTSC, Water Quality, U.S. EPA, CIWMB and Air Quality were available
to respond to any questions or comments from the public.
City comments were sent to DTSC on February 10, 2000. The next step in
the process is for DTSC to respond to all comments and take action on the
permit. DTSC has received a total of approximately 850 comments to
which they are currently preparing responses.
BKKSTATUS a9 Note: Class I = closed hazardous waste landfill.
SLs Class III = closed household waste landfill.
01/08/01 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
t
STATUS OOLANS FOR BKK LANDF& CLOSURE
as of January S, 2001
BKKSTATUS 49 Note: Class I = closed hazardous waste landfill.
SLS Class III = closed household waste landfill.
01/08/01 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
H
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1-1�C1t�C
CORPORATION
August 25, 2000
Via Certified Mail Z 273 622 195
Steven L. Samaniego, R.E.H.S.
Environmental Management Director
CITY OF WEST COVINA '
1444 West Garvey Avenue South
West Covina, CA 91793
2210 South Azusa Avenue
West Cw ma. Califanua 91792
(626)965-0911
Fax (626) 965-9569
AU6 2 8 2000
atyof west come
Re: Schedule for Phase C Landscaping on Class III Landfill at BKK Landfill Site'
Dear Mr. Samaniego:
In response to your July 28 request, we are herein elaborating on the information provided
in our May 31 and July 6, 2000 submittals regarding the schedule for Phase C landscaping
on the Class III landfill at the BKK Landfill site. We address each of the six items in your
recent letter (copy attached) below.
In response to your previous request, our July 6 submittal was couched in the form of an
application to modify the Partial' and Final' Closure Plans for the Class III landfill'. The
11
additional details presented today should provide you with the information necessary to
approve that application (copy attached). As you know, it is also necessary forpCIWMB
and RWO.CB to approve an application to modify a closure plan.
I�
By copy of today's letter, we are asking Doug Mctsaac to also approve our application.
This entreaty to Mr. Mclsaac is done in response to your request in Item No. 5 below.
1. Identify via blue prints the estimated portion of Phase C not impacted by'; the golf
course development.
It is difficult at this -point in time to identify any significant piece of the visible
portion of Phase C that will not be impacted by the golf course development. It is
the uppermost two slopes of the northwest corner of Phase C that are most visible
from a handful of offsite vantage points. There currently are two constraints to the
placement of landscaping in this area:
First, as you and l .discussed during your tour in early August, many
'consti•udtion arctivities are expected to occur in and around the northwest
�I
' Partial Final Closure and Postclosure Maintenance Plans, BKK Sanitary Landfill, Class Ill
Disposal Area, December 1994 (BKK Corporation, Revised October 1996).
' Final Closure and Postclosure Maintenance Plans, BKK Sanitary Landfill, Class 111 Disposal
Area (BKK Corporation, Revision 2: November 1997).
J
August 25, 2000
Steven L. Samaniego, R.E.H.S.
Page Two of Four
corner of Phase C. Not only will the proposed golf course overlie part of the
area, but other parts of the area are expected to be traversed by a temporary
haul road that will be used to support construction ,of the top deck cap
(Phase E) as well as a good portion of the rest of the golf course: -
And second, the final layout of the golf course is still in flux. The design
cannot be finalized until the City grants or denies land use entitlements for
the property. The tentative layout has already been changed once (by
reducing the size of the project in order to move off the North Ridge). BKK is
continuing to request that it not be required to proceed any further until the
layout can be resolved.
We do have a revised proposal, however, which would add some aesthetic
landscaping to the most visible portion of largely -hidden Phase C. Please see Item 2
below.
2. Within 14 days, landscape that portion of Phase C not. impacted by the golf course
once identified in accordance with the approved Partial Final Landscape Plan.
BKK proposes to resolve the aesthetics issue by offering to place approximately 40
mature trees in containers along the northwest nose of Benches E and F (the bench
roads at the base of the uppermost two slopes). These trees would be temporarily
moved from our onsite nursery and placed approximately ten feet apart on the outer
edge of the noted bench roads. The result would be two approximately 200-foot
swaths of mature trees along the portion of the Phase C that is most visible from a
handful of .offsite vantage points. See the attached depiction of the area which is
proposed to receive the temporary trees.
Once the golf course layout is finalized and the logistics of the construction haul
road have been ironed out, BKK will remove the temporary tree screen and install
permanent landscaping in the unaffected portion of Phase C.
If this approach is acceptable, we will commence temporary tree placement
activities within 14 days of approval, and we will complete this work within 45 days
after we start. .
3. Submit more detailed information on both temporary erosion control landscape time
schedules, seed palette, irrigation, maintenance criteria with respect to inspection
access, visibility and fire control management.
This information augments that which was provided in our July 6 package. If the
determination on the golf course is not resolved by the start of the rainy season,
BKK will hydroseed Phase C for erosion control by October 15, 2000. This will
augment the existing nondesign vegetation which was sufficient for Phase C to
August 25, 2000
Steven L. Samaniego, R.E.H.S.
Page Three of Four .
successfully withstand last Winter's rains. The act of hydroseeding shouldl only
take two or three days to complete. It should not be put in place too early (in the
heat •of the Summer); because. Fall rain is the predominant method used to water the
`seeds and thereby establish root growth in order to control erosion.
The temporary erosion -control seed palette is the same as that which the City has
approved and BKK has used in past years. The palette is also the same as is
commonly used on other landfills in California. The seed to be used is annual rye
grass. The hydroseed mix will have at least a 50 percent purolized seed content,
defined as the product of the tested seed purity multiplied by the tested seed
germination rate. 11
Permanent irrigation systems will not be installed for the temporary rye. Natural
rainfall will be augmented by irrigation from a water truck (or similar) as necessary
to ensure seed germination.
If seeded, the temporary rye in Phase C will be maintained in a similar manner as are
other areas of the Class III landfill in which the final landscape system has not yet
been put into place (i.e., Phases D and E). This maintenance applies to inspection
access, ground visibility and fire control.
4. Include an alternative plan if the golf course is not approved. The alternative plan
should reference that the remainder of Phase C will be landscaped in accordance
with the. existing landscape plan within a specified schedule of the City Council's
action.
If the golf course development is not approved, BKK is already required to install the
"standard" (non golf course) landscaping in Phase C in accordance with the
approved Partial and/or Final Closure Plan(s).
5. Include the City of West Covina's written approval of BKK's proposed amendment.
We have asked Mr. Mclsaac to provide written City approval. We will transmit a
copy of that letter back to you upon receipt.
6. The amendments shall be submitted in a form that the revised pages may be
inserted into the approved Partial Final Closure Plan landscape chapter and
attachment with instructions of what pages should be replaced.
As you and I discussed the day before yesterday, the longstanding practice of the
annual application of temporary erosion -control rye grass on unvegetated slopes is
already addressed in the Closure Plan. This leaves the remaining issue of the
temporary tree screen presented in Item 2 above. As discussed, it is probably not
worthwhile (for all parties) to issue revised Closure Plan pages just to reflect the
0 0
1
August 25, 2000
Steven L. Samaniego, R.E.H.S.
Page Four of Four
temporary tree screen. W1lhile.we are still complying with your request -to apply for
modifications to the Partial and Final Closure Plans, 6dr request is couched in the -
'form of.our July 6 and today's letters rather than in the form ofrevised Closure Plan -
insert pages. -
Thank you for your attention to this matter. We hope today's letter meets your needs. We
will move forward once we receive the necessary approvals from you, Mr. Mclsaac, Gino
Yekta of CIWMB, and Wen Yang of RWQCB.' If you have any questions or need further
information, please do not hesitate to call me at (626) 965-0911 extension 353.
Sincerely,
BKK CORPORATION
Kelly cGregor
Vice President and General N14ager
Attachments: [1 ] Copy of July 28, 2000 letter from City
[21 Copy of July 6, 2000 letter from BKK
[31 Figure Depicting Area to Receive Temporary Trees
cc: Chris Hansen - BKK Corporation, West Covina CA
Dan Hobbs - City of West Covina, West Covina CA
Ken Kazarian - BKK Corporation, West Covina CA
Doug Mclsaac - City of West Covina, West Covina CA
Blythe Ponek-Bacharowski - RWQCB, Los Angeles CA
Pete Soriano - BKK Corporation, West Covina CA
Alan Tuntland - BKK Corporation, West Covina CA
Scott Walker - CIWMB, Sacramento CA
Peter Weiner - PHJ&W, San Francisco CA
Wen Yang - RWQCB, Los Angeles CA
Gino Yekta - CIWMB, Sacramento CA
File
3 The RWQCB approval has already provided via an August 21, 2000 letter from Rod Nelson
to Kelly McGregor.
0
;L-28-00 FR1 16:63
July 28, 2000
ENV SVCS/Wr.STE M0 T E`iF
Mr. Kelly McGregor
Vice President/General tiianaaer
BKK Landfill
2210 South Azusa Avenue
West Covina, CA 91792
FAX NO. 6268138663
Re: Partial Final Closure Plan Phase C Landscaping Amendment
Dear Mr.1vIcGmgor
P. 02
CENTRAL FILE
e
BKK LAND FILL
L 2 8 2001.,
The Waste M- anagement Enforcement Agency (W.NtEA) has received your letter dated
July 6, 2000 rcga.rding the Phase C Landscaping. The WNI A supports BKK's temporary erosion
control vegeation proposed amendment to the Partial Final Closure plan. {¢,
Prior to the WLiEA's approval of BKK's Proposed Peal Final Closurz Plan Amendment, BKK
shall submit the following; p
1. Identify via blue prints the estimated portion of Phase C not impacted by the golf course
development
2. Within 14 days, landscape that portion of Phasc C not impacted by the golf course once'
identified in accordance with the approved Partial Final Landscape Plan.
3. Submit more detailed information on both temporary erosion control landscape time schedules,
sr ed palcµe, irrigation, maintenance criteria with respect to inspection access, visibility and fire
control management
4. Include an alternative plan if the golf course is not approved. The alternative plan should
reference that the remainder of Phase C will be landscaped in accordance with the existing
landscape plan within a specified schedule of the City Council's action.
S. Include the City of Went Covina's written approval of BKK's proposed amendment
6. The amendments shall be submitted in a form that the revised pages may be inserted into the
approved Partial Final Closure Plan landscape chapter and attachment with instructions of what
pages should be replaced._
It is recommended that a draft copy of the amendment page inserts.be submitted for review,prior to
our approval. If you have any questions please call me at (626) 814-9411.
Sincerely, ;
r l
Steven I— Samaniego
Environmental Management Director
SLS:hr
cc: Gino Yckta, CIVnvfB
Wen Yang, RWQCB
Doug Mclssac, West Covina Planning Department
I511a�C
CORROR =TION
July 6, 2000
Steven L.-Samaniego, R.E.H.S.
Waste Management Director
CITY OF WEST COVINA
1444 West Garvey Avenue South
West Covina, CA 91793
C(OPY
Wen Yang, Ph.D., C.H.G., C.E.G.
Associate Engineering Geologist
REGIONAL WATER QUALITY CONTROL BOARD
320 West 4' Street, Suite 200
Los Angeles, CA 90013
2210 south Azusa Avenue '
West Covina. California 91792
(626) 965-0911
Fax (626) 965-9669
Via.Certified.Mail Z 273 622 167-
Via Certified Mail Z :173 622 168
Gino Yekta Via Certified Mail Z 273 622 169
Waste Management Engineer
INTEGRATED WASTE MANAGEMENT BOARD
8800 Cal Center Drive
Sacramento, CA 95826
Re: Schedule for Phase C Landscaping on Class III Landfill at BKK Landfill Site
Dear Messrs. Samaniego and Yekta and Dr. Yang:
In response to a June 6, 2000 request of Mr. Samaniego, BKK Corporation is herein
augmenting a recent schedule update by asking for a formal modification to the Partial' and
Final' Closure Plans for the Class III landfill at the BKK Landfill site.
The Partial Final Closure Plan is the document that is currently in effect. It gives approval
to proceed with closure of Phases A, B and C of the five -phase construction project. The
remaining Phases D and E are addressed in the Final Closure Plan, and that: plan has not yet
been given the last of its necessary approvals via the ongoing CEQA process.
The construction of Phases A and B is largely complete. And, other than for landscaping,
the bulk -of Phase C -construction is complete as well. Once Phase C landscaping is done,
nearly all of the currently -approved closure work will have --been completed.
'Partial Final Closure and Postclosure Maintenance Plans, BKK Sanitary Landfill, Class l!1
Disposal Area, December 1994 (BKK Corporation, Revised October 1996).
2Final Closure and Postclosure Maintenance Plans, BKK Sanitary Landfill,. Class l/l Disposal
Area (BKK Corporation, Revision 2: November 1997).
•
CJ
July 6, 2000
Steven L. Samaniego, R.E.H.S., et al
Page Two of Three
C(OPY
Phase C landscaping was held up at the close of last year's construction season due to
unresolved performance issues related to the contractor's recently completed work, on..
preceding Phase B. However, with that issue now resolved, it appears that we may be
nearing'a determination by the City of West Covina on -land use entitlements for a_ proposed
-golf course that partially overlies the top deck of the closed Class III landfill. 'The
determination on the golf course will directly impact the landscaping on Phase C. The
landscaping will vary in both footprint and plant palette based on whether or not the golf
course proposal is approved. Accordingly, because the City's decision may occur in the
relatively near future, we have asked to temporarily postpone the landscaping installation
on Phase C. It makes no sense to install pipes, sprinklers, trees, bushes and hydroseed
today if those materials may very well have to be dug up and reinstalled somewhere else
tomorrow.
BKK Corporation is herein asking that the Tentative Schedule in Section 3 of the Partial
Final Closure Plan be revised as follows:
1. If the determination on the golf course is not resolved by the start of the rainy
season, BKK will establish temporary erosion -control vegetation on Phase C by
October 15, 2000. This temporary vegetation will consist of preexisting locally
blown -in species, plus rye grass and/or other hydroseeded groundcover species as
appropriate. This is the industrywide standard for erosion control on unvegetated
landfill slopes. The temporary vegetation will remain in place until it is superceded
by the design landscaping at a later date (see Item 2 below).
2. On the other hand, if the determination on the golf course is resolved by the start of
the 2000/01 rainy season, BKK will submit a revised Phase C construction schedule.
The schedule will reflect the final approved golf course configuration, and will
specify the time necessary to install landscaping on the other portion(s) of Phase C.
Please note that it is premature to develop a revised Phase C landscape schedule
until the golf course. footprint and plant palette are finalized. Please also note that
temporary erosion -control vegetation may still be appropriate depending on the
timing of the golf course determination.
Please refer to Task Nos. 103 and 108 of the Tentative Schedule regarding Phase C
landscape installation. Those are the items which are proposed to be modified via today's
letter.
A third scenario was considered in addition to the two listed above. The City's Waste
Management and Environmental Quality Commission asked in its June 15, 2000 regular
monthly meeting that BKK also consider another approach. Their proposal was for the
immediate installation of the design hydroseeded groundcover and irrigation system in
Phase C, but without the accompanying installation of the containerized/mature''bushes and
trees. After careful consideration we determined that this proposal defeats the purpose of
the first two proposals (which is to avoid doing the same work twice). The third proposal
s
July 6, 2000
Steven L. Samaniego, R.E.H.S., et al
Page Three of Three
adds little aesthetic and erosion -control value to Phase C, while it runs the risk that the
same irrigation system might have to be installed twice and hydroseeded groundcover*
might have to be destroyed and re -seeded elsewhere. - Please keep in mind that the entire
cQncept-behind waiting for the golf course determination is to avoid.the 'need to remove
and reinstall the irrigation system and destroy freshly -placed vegetation.
Please note that the benefits of the third proposal are similar to Item 1 above as it relates
to erosion control, and are essentially moot with regard to aesthetics in largely -hidden
Phase C.
Thank you in advance for your attention to our request to modify the Phase C landscape
schedule in the Partial Final Closure Plan. If you have any questions or need additional
information, please do not hesitate to contact me at (626) 965-0911 extension 353.
Sincerely,
BKK CORPORATION
Kelly P.QcGregor
Vice President and General Manager
cc: Chris Hansen - BKK Corporation, West Covina
Dan Hobbs - City of West Covina, West Covin,
Ken Kazarian - BKK Corporation, West Covina
Doug Mclsaac - City of West Covina, West Co -
Blythe Ponek-Bacharowski - RWQCB, Los Ange
Pete Soriano - BKK Corporation, West Covina C
Scott Walker - IWMI3, Sacramento CA
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