01-03-1995 - BKK Landfill Regulatory Requirements on Gas & Water Well DecommissioningCity of West Covina
Memorandum
AGENDA
E_1
ITEM NO.
DATE January 3, 1995
®PRINTED ON RECYCLED PAPER
TO: City,Manager and City Council
FROM: Steven L. Zamaniego
Waste Management Enforcement
Agency Manager
SUBJECT: BKK LANDFILL REGULATORY REQUIREMENTS ON GAS AND WATER
WELL DECOMMISSIONING
SUMMARY: At the December 20, 1994 City Council meeting, the Waste
Management Enforcement Agency was asked to submit a
report on the procedures BKK followed for the removal or
decommissioning of gas wells within the North Area Design
Excavation.
BACKGROUND
The Stipulated Permanent Injunction of 1988 regulates the
decommissioning of gas wells at the BKK Landfill. BKK is required
to obtain prior approval in writing from the California Integrated
Waste Management Board (CIWMB) before deactivating any wells.
However, for the reasons set forth in Attachment I from the CIWMB,
BKK was not required to obtain prior approval.
The Calif ornia,J well. standards by the State Water Resources Control
Board requires'BKK to obtain permits from the Department of Health
Services for abandonment of water wells and also construction of
water wells. Attachment II indicates that the water wells CW24A
and CW25A werelon the approved list for decommissioning.
The responsible agencies, CIWMB and Regional Water Quality Control
Board (RWQCB) have informed me that BKK is in compliance with water
well and gas well abandonment requirements.
The following attachments are responses from CIWMB, RWQCB and BKK.
regarding the decommissioning of gas and water wells:
Attachment I - CIWMB Memorandum Dated 12-28.-94
Attachment II - Proposed Well Decommissioning Schedule
Attachment III - BKK Letter Dated 12-28-94
It is re
report.
that the City Council receive and file this
c:
Steven L. Samaniego
Waste Management Enforcement
Agency Managers
Attachments
DEC-27-1994 16:48 �
•
CIWMB
• ATTACHMENT I
916 255 1069 P.01
State of Califi
MEMORAN
To:
From:
a
D U M
Post -It" brand fax transmittal memo 7971
Mr. Steven L. Samaniego Date: December 27,
City�,of West Covina
Solid''Waste Local Enforcement Agency
SCQtt. Walker, Manager
Closure and Remediation Branch North Section
CALIkRNIA INTEGRATED WASTE MANAGEMENT BOARD
Subject: BKK Landfill, Board Staff Letter of December 13, 1994
The following addresses your question concerning California
Integrated Waste Management Board (Board) staffs (Mr. Tim Crist)
letter to you dated December 13, 1994. Specifically, you ask
for verification that the Stipulated Permanent.Injunction (SPI)
was followed regarding the abandonment of the K series gas
extraction wells and replacement by the ten.new extraction wells
on the interior north perimeter of the Class I landfill. Also
noted in the letter is that gas probes along -the north boundary
were replaced lifter being destroyed during North Area step out
excavation.
Exhibit I, Page iii, Part ID (Landfill Gas System Maintenance
Requirements) of the SPI states: . . any broken or inoperable
monitoring probes or gas collection wells shall be replaced
within 30 days''of detection, unless BKK can demonstrate to the
CwmiB that the monitoring probes/gas collection well is
unnecessary for effective landfill gas migration control due to
newer monitoring probes located outboard of the area or,
redundancies built into the landfill gas migration control system
or for any other reaeona." However, Page v, Part IV (Procedures
for Deactivation of Gas Collection wells) of the same exhibit
states: 11BKK must receive prior approval in writing from the
CWMB before deactivating any wells. However, BKK must continue
to monitor and'�maintain all existing and future perimeter
monitoring probes."
The K series gas extraction wells would.be considered to.have
been "inoperable" rather than having been "deactivated" because
they never produced gas (never active), as indicated in the
December 13, 1994 letter. Therefore, the SPI would not require
prior Board (CWMB in SPI) written approval for abandonment and
replacement of'those wells. Furthermore, prior Board written
approval wouldlnot be required for installation of the
replacement gas probes since they were destroyed ("broken") and
not '"deactivated". Based on Board staff review, BKK's response
was adequate in meeting the Board's requirements.
j {
PROKAP WELL X»GC)MMISSIONING SIWDULE ATTACHMENT II
FOK EPA APPROVED LIST OF 42 W IS
0
YEAR
MONTH
MONITORING WELLS COMPLETED
1992
AUGUST
OP-30A
1994
MAY
CW-24A
JUNE
CW-25A, CV-26A
OCTOBER
MW-16P 1, MW-16P2
NOVEMBER
MW-16, ?dW-16P3, EO-1
DECEU BER
cw-8A, OP-32A► OP-3Z% OP-32C
1995
JANI jARY
MW50AR, OP 13, OP-15 A, OP-18
FEBRUARY
&lid/-20B, MW-20D, MViI-23AR
MARCH
CW-39A, EP4: MW-17A
APRIL
OP-29A, OP 29B, OP28A, OP-28B
MAY
MW-25A, MW-25B, MW 21A, MW-21B
JUNE
OP-30B, OP-30C, OP-31A, OP-31B
JULY
MW-35A, MW 35B, MW35C
AUGUST
MW 21A, MW-21B, MR-03, MR45
SEPTEMBER
OP-27A, OP-27B
Post -It'" brand fax transmittal memo 7671
f o1 pages 10
R"�/
pt'
-c7
p e[ iFbx#
S311MN
•
1��K�KC
CORPORATION,
Mr. Steven Saminiego
Waste Management Enforcement Manager
City of West - Cowna
1444 West Garvey. Avenue
P.O. Box 1440
West Covina, Q lifornia 91793
Re: BKK Landfill
Dear Mr.
ATTACHb& III
Der -ember 28, 1994
and Gas Well Abandonment
BKK Landfill
2210 South Azusa Avenuo
VVW Qftina- CaMunia 91792
(818) 965-091I
rmx: (81a) 965.9"s
Groundwater monitoring wells CW24A and CW25A were determIined to be no
longer useful under the RCRA Facility Investigation studies being conducted by BKK
and the U.S. En nmental Protection Agency (EPA), and were abandoned with the
approval of EPA in accordance with an EPA -approved workplan. A county health
department pesnut was issued fdr each well abandonment.
The eight �g'as collection wells at the end of the "K" Line Header were
abandoned becauie they did not collect landfill gas, and were inoperable. The.
remaining wells, of the "K" Line produce gas, and other wells inboard ' (south) of the
"K" Line produce gas. Gas probes in the North Saddle Area have all indicated
satisfactory gas collection system performance for many years. Several gas probes
along the northern boundary of the property were destroyed during excavation earlier
this year. Those 1probes were replaced.
If you hay I e any questions, Please call me at (818) 965-0911
Sincerely,
-TION
Regulatory and Environmental Compliance
cc: Tim Crist IWMB
Scott Walker, C1WMB
klawfiAk-fins.1jr