02-07-1995 - BKK Landfill Data Supporting Abandonment of "K" Line Gas Collection Wells & Responses to Mrs. Jean Arnesons' Questionsl
city of West Covina
Memorandum
i Manager and City Council
TO: City g Y AGENDA
ITEM NO. E-1
FROM: Waste Management Enforcement Agency DATE February 7, 1995
®PRINTED ON RECYCLED PAPER
SUBJECT: BKK LANDFILL DATA SUPPORTING ABANDONMENT OF
"K" LINE GAS COLLECTION WELLS AND RESPONSES
TO MRS. JEAN ARNESON's QUESTIONS
1
SUMMARY: At the January 3, 1995 City Council meeting, the Waste Management
Enforcement Agency was asked to obtain records supporting that the
I K-line gas wells were not producing any gas and to include a
I of the "K" line gas wells. The January 17, 1995.report to the
Council states that further research was needed by the CIWMB prior to
responding. Upon further research, the CIWMB has responded by
concluding that BKK had complied with the Stipulated Permanent
BACKGROUND
At the January 3, 1995 City Council meeting, the Waste Management Enforcement Agency
(WMEA) reported the at according to the California. Integrated Waste Management Board
(CIWMB) and the Regional Water Quality Control'Board Los Angeles (RWQCB-L.A.), BKK
was in compliance with water and gas well abandonment requirements. Mrs. Jean Arneson.
raised the question asking for the records on the "K" line gas wells confirming that they never
produced gas and were inoperable.
The LEA requested from the CIWMB the data on the gas wells and responses to Mrs. Arneson's
questions. The CIWMB was unable to give a response and would have to research records prior
to responding.
It appeared on the surface of the LEA's review that the Stipulated Permanent Injunction may
have been violated due to the lack of records but would require further review and investigation
for confirmation.
Per the attached letter'dated January 23, 1995, the CIWMB reviewed the data submitted by BKK
on the gas wells and concluded that even though the CIWMB was not notified of the inoperable
gas wells, the data provided by BKK indicates that the well abandonment was the proper thing
for BKK to do. Therefore, the CIWMB concluded that BKK has satisfied the Stipulated
Permanent Injunction 1 although not in the most timely manner.
Mr. Tim Crist of the CIWMB suggested that if Mrs. Arneson or, other interested citizens had
further questions regarding this topic to submit them in writing to him and he will respond. The
data submitted by BKK is available in the WMEA's office .for public review.
It is recommended that the City Council receive and file this report.
G
Steven L. Samaniego,1 R.E.H. .
Waste Management Enforcement Manager
Attachment
ATS OFX:At1FORNU
Pete wflM11- r.8VAr4er
CALIFORNIA INTEGRA
UM cm Conmr Drive
Seaamento, 4lifomia 95826
January 23, 1995
WASTE MANAGEMENT BOARD
Mr. Paul W. Neff
Director, Regulatory and
Environmental Compliance i
BKK Landfill
2210 South Azusa Avenue
West Covina, CA 91792
ATKK T.mrnrifi 1 ? _ �7_TA rs 4 1 L+; 1
In response toIrecent inquiries from the Local Enforcement Agency
and local residents, (,lean Arneson), regarding the
decommissioning of several K-Line gas extraction wells, I
requested that BKK submit operational data and other pertinent
information for �the. wells in question. This request was made
verbally on December 14th during a site visit to BKK. The
requested information was received oh January 17, 1995. I have
since reviewed the submitted data.
The submitted data and report, clearly indicate that K-Line
wells, WK-11 thru WK-19 were not operating as originally
designed. These wells were actually drawing gas from the
landfill rather, than capturing gas which was escaping. This
happened as a result of the installation of a new gas extraction
grid in the Class III landfill sometime prior to November of
1989. The Class III gas grid has effectively controlled gas
migration to the areas of the noted K-Line wells. Since the
operation of these wells would be counter productive to
effectively containing the landfill gas within the waste mass,
these wells werje deemed inoperable and taken out of service
sometime after December of 1991. In conversations with BKK
staff, it is my, understanding that the wells were back filled
,with a cement grout in accordance with standard well abandonment
practices.
As a point of. .interest, the records show that the wells were
actually installed as well pairs, e.g. WK-11 (a deep well) had a
corresponding co -located shallow well WK-11SW. These wells were
put in during the infant days of gas extraction technology based
on the postulate that gas extraction could be considered
analogous to water extraction. However, the practice of
installing multi -level extraction wells has been superseded by
single well bores which are perforated in the desired subsurface
extraction zone and have proven to be just as effective and of
considerable less expense. The records did indicate that the
deeper wells, (which ranged in depth from 120 feet to 150 feet),
produced more gas than the shallow wells, (depths.not recorded
but probably in the order of 20 feet to 50 feet).
0
Printed an Recydvd Paper •-
Mr. Paul Neff
Page 2
77`Zaarch of the Board facility tiles indicates that there was no
official communication between November 1989 and December 1992
regarding the status of the K-Line.wells. Although the Board was
not notified in writing at the time the wells were deemed
inoperable, the data presented by BKK indicates. that this was the
proper conclusion and there appears to be no reason why the Board
staff would not have concurred with this conclusion. Therefore,
I conclude that BKK has satisfied the Stipulated Permanent
Injunction and that the above noted K-line wells may be deemed
inoperable and can be abandoned in accordance with standard well
abandonment practices.
If you have any further questions, please contact me at
(916) 255-2332 or Scott Walker at (916) 255-2343.
Sincerely,
Timothy W. Crist, P.E.
Closure and Remediation Branch
Permitting and Enforcement Division
TWC:twc \bkk\1tr21.doc
cc:. Ms. Lillian Kelly
Office of Environmental
Health Hazard Assessment
601 N 7th St.
Sacramento CA 94234
Blythe Ponek-Bachorowski
LA Regional water Quality
Control Board
101 Centre Plaza
Monterey Park CA 91754
Mr. Steve Samaniego
Waste Management
Enforcement Manager
City of West Covina
1444 West Garvey Avenue.
West Covina, CA 91793
Mr. Richard Tambara
South Coast Air Quality
Mgmt Dist
21865 Copley Dr
Diamond Bar CA 91765
Mr. Allen Sorscher
Dept. of Toxic Substances
Ctrl
1011 N Grandview
Glendale CA 91201
Ms. Carmen D. Santos
EPA
75 Hawthorne St
San Francisco CA 94105
bcc: Scott walker - Closure and Remediation Branch