01-20-2004 - BKK Landfill Closure Plans - Monthly Status Report11
• CITY of West Covina
Memorandum
AGENDA
ITEM NO B-69
DATE: January 20, 2004
P
TO: Andrew G. Pasmant, City Manager and
City Council
FROM: Steven L. Samaniego
Environmental Management Director
SUBJECT: BKK Landfill Closure Plans
Monthly Status Report
lip
RECOMMENDATION:
It is recommended that the City Council receive and file this report.
DISCUSSION:
This is an updated report on the STATUS OF PLANS FOR BKK LANDFILL
CLOSURE and other related BKK matters. 1
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.
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. g
LandscaP in 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
FISCAL IMPACT:
None.
r
Steven L. Samaniego, R.E.H.S..
Environmental Management Director
Attachments: Status of Plans for BKK Landfill Closure
i
bkk/stat8 I
SLS
1 /20/04
PRINTED ON RECYCLED PAPER
STATUS OALANS FOR BKK LANDIL CLOSURE
as of January 20, 2004
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 ijof
the Grading Plans, BKK will continue the grading along Azusa Avenue for
landfill cover soils. The we ridgelines highest elevation point priorJo
grading was approximately 675 .feet. Since the grading, the current
elevation as of Wednesday, October 13, 1999 is approximately 650 feet.
Therefore, BKK has graded approximately 25 feet of the hillside.
2. 1 LANDSCAPING OF CLASS III LANDFILL
The landscape work has been divided into five major phases, termed
Phases A through E (see attached map). Phase A and B landscape work
has been completed. In February and March 2001, California Integrated
Waste Management Board, Regional Water Quality Control Board and
Local Enforcement Agency approved BKK's revision to the- Partial Final
Closure Plan to defer Phase C Landscaping until the golf course is built.
The California Integrated Waste Management Board on April 12, 2001
approved BKK's . proposed Partial Final Closure Plan Landscape iC
amendment ' to hydroseed and install a temporary screen of boxed trees
along the second and third uppermost benches at the northwest corner of
Phase C. The tree screening was completed in May 2001. Landscaping of
the remaining Phases D and E are elements of the Final Closure Plan (See
Item 7 below).
Phase A Slope C west facing in the central portion has a sparse number 11
of
trees planted from pots. BKK has agreed to plant some additional trees on
that slope during the Phase C landscaping when the golf course is
completed.
Weeding on the Class III Landfill is often very slow. Weeds have been
allowed to get tall, thick, flower and seed before weeding. Tall weed's
hinder irrigation coverage and inspections. The bermuda grass has been
spreading without adequate weed control management by BKK. It appear's
that the weeding crew is not adequately, staffed to manage the weeds,
although BKK does eventually weed and mitigate the problem.
Many trees have grown pretty tall and are in need of trimming. BKK has
trimmed some but there are still many that need trimming. Some trees that
are too close to environmental. lines such as down drains, gas lines etc.
need to be trimmed or removed for access and inspection. This is an
ongoing program that is addressed during inspections.
3. 1 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, after which the City met with BKK in December 1999.
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.'
BKKSTATUS 81 Note: Class I = closed hazardous waste landfill.
SLS Class III = closed household waste landfill.
t/2oioa DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
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STATUS ORLANS'FOR BKK LAND#LL CLOSURE
as of January 20, 2004
City in February 2000, a draft joint CityBKK document, which seeks
DTSC's clarification regarding the conditions under which the State will
allow the planting of trees _on the Class I landfill. City staff has met on
July 22, 2003 to discuss the plan and process of obtaining DTSC's
approval.
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 potable water and smaller amounts of reclaimed
site water. While not planning to alter the water mix 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. City staff will be preparing a response to BKK,
which is anticipated to be completed the first quarter of 2004.
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. In April 2000 BKK requested an
extension, which is awaiting the City's response, which is anticipated to be
completed the first quarter of 2004.
5.
AZUSA FRONTAGE SCREENING
If BKK proposes to excavate the westerly ridgeline below the trigger
elevation 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 under -ground
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 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. The plan is
pending City's approval, which is anticipated to be completed the first
quarter of 2004.
7.
CLASS III LANDFILL FINAL CLOSURE AND POSTCLOSURE PLAN
The first three (A, B and C) of the five major final closure construction
phases (A, B, C, D and E) have been completed under the approved Partial
Final Closure Plan. The Final Closure and Postclosure Plan covers those
three plus the remaining two construction Phases D and E (see attached
BKKSTATUS s1 Note: Class I = closed hazardous waste landfill. 2
sLs Class III = closed household waste landfill.
1/20/04 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
STATUS OPLANS FOR BKK LANDAL CLOSURE
as of January 20, 2004
map).
In October 2000 the City Council certified the Final. Environmental Impact
Report for the Final Closure, Postclosure and Development of the BKK
Landfill. The Waste Management Enforcement Agency (WMEA) for the
City of West Covina has approved the Final Closure Plan, incorporating', by
reference, the EIR Mitigation and Monitoring and Partial Final Closure
Plan amendments that apply. The WMEA's approval requires BKK to
coordinate the grading and schedule of closure -with the City's planned
development of the Big League Dreams project and that the final cover
design comply with the 1996 Settlement Agreement. `1
BKK has proposed -a variance in the Final Closure Plan for the final cover
design from what is required per the 1996 Settlement Agreement. It is for
an 8.8-acre area of Phase -D below the main haul road. The existing cap
was constructed in the early 1990's (before the 1996 Settlement Agreement
was signed). Rather than dig it up and replace it with the required 7.5 ft.
of vegetative soil layer, BKK is proposing to leave the existing final clay
cover soil in place.
This 8.8 acre area of existing cover exceeds the State minimum
requirements on final cover. The existing cover in place meets the
Settlement Agreement soil depth requirements, but does not meet the
required soil composition. BKK installed an 8.5 - 10 foot thick layer "of
clay rather than 1 foot of clay overlain by 7.5 feet of vegetative soil, as
required by the Settlement Agreement. BKK believes that the need for
vegetative soil is not nearly so important because it is largely hidden from
view.
The WMEA is requiring that the final cover design meet the Settlement
Agreement criteria having a 7.5 foot layer of vegetative soil landscaped
with.trees and groundcover unless BKK obtains a written variance from the
City. City staff met on July 22, 2003 and will prepare a response to BKK:
8. 1 CLASS I LANDFILL POSTCLOSURE PLAN .
The closed Class I Landfill has been operating since 1998 in accordance
with DTSC postclosure regulations, but DTSC has yet to issue a site -
specific postclosure permit. DTSC released a draft permit for public
comment in November 1999, and then held a public hearing in December
and a community meeting in January 2000.
City comments were sent to DTSC on February 10, 2000. The next step i,n
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.
Prior to taking action on the permit, DTSC will:
1. Write responses to all comments.
2. Craft additional permit conditions in response to comments.
3. Implement an internal review of the Draft Permit.
4. Have BKK review Draft Permit.
5. Make the decision on the final permit and public notice the decision.
6. Mail notices of the Decision and Response to Comments to those that
commented.
Per DTSC, the Post Closure Draft Permit completion is behind schedule. It
is undergoing internal peer and legal review for consistency with other
BKKSTAT1 N RI NntP• (']nee T = ..I., A 1,—.L,, ... +_ I AIC
SLS Class III = closed household waste landfill.
1/20/04 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board
N
STATUS UALANS FOR BKK LANDFILL CLOSURE
as of January 20, 2004
documents and clarification changes. The time delay is the Agency's issue
due to limited staff resources. The expected date of completion has passed.
The City has no enforcement authority to resolve this issue.
9. UNCAPPED SLIVER OF BURIED WASTE
Attached is a letter from BKK dated January 29, 2003 disclosing that they
found some uncapped buried trash located just outside of the northeast
corner of the Class I Hazardous Waste Landfill. BKK's report states that
the trash was buried there in the mid=1980's without a liner or final cover
cap. BKK's report: states' that the waste is non -hazardous and that they are
proposing to leave the waste there and extend the existing Class I final
cover cap over the waste for closure.
The. Department of Toxic Substances Control (DTSC) will. take the lead
and cap the waste in accordance with, and as a continuation of, the Class I
;Landfill Final Closure Plan.
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Ficure 1
.f CLOSURE CON`=T[<UC'nOR F',•-iAL-E
SKK CORPORATIO-N
BKKSTATUS 81 Note: Class I = closed hazardous waste landfill 4
SLS Class III = closed household waste landfill.
1/20/04 DTSC = California Department of Toxic Substances Control
USEPA = United States Environmental Protection Agency
CIWMB = California Integrated Waste Management Board