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General Comments
How do the "General Categories of Factors" relate to the table? Please explain.
Specific Comments
Proximity to Urban Areas
- What definition of "urban" is being used? Is the measurement from
the closest "urban" boundary? Is it measured to the facility boundary or
the disposal area boundary? Some approved urban density measurement is
needed otherwise one house could trigger an urban area.
Amount of Waste in Place (See additional comments on table:
Adobe PDF, 38 KB | MS
Word, 112 KB)
- What is the cutoff between large and small landfills?
- Another quantitative parameter should be the current daily tonnage
input since a landfill could have a large volume of waste in place but
the current rate of accepting wastes and/or the final design/permitted
capacity could be limited such as nearing capacity. Conversely, a site
with a small amount of waste in place could be approved at a much larger
rate of incoming wastes.
- Perhaps this factor should be separated into current waste in place
versus final permitted capacity.
Type of Waste in Place
- How will this criteria address sites that have been converted from
municipal solid waste (MSW) to construction and demolition (C&D) sites?
Hydrogeology
- How about intermediate potential impacts such as low permeability,
high groundwater?
- This factor should also assess the potential for impacts when the
first groundwater is confined and not accessible to potential users.
Rainfall
- The control/mitigation comment of engineering design is very broad
and needs to be expanded.
- This factor also needs to consider storm water runoff and control
measures implemented to direct and contain the water.
Potential for Flooding
- The control/mitigation comment of engineering design is very broad
and needs to be expanded.
- Will this factor consider the differences between flooding on site
versus flooding in the surrounding area that could be diverted from the
landfill?
Proximity to Sensitive Habitat
- The control/mitigation comment of engineering design is very broad
and needs to be expanded.
Compliance Status
- This factor should differentiate between paperwork compliance versus
state minimum standards or other operational issues. A landfill could be
in total operational compliance but the permit is not current due to
circumstances.
- We strongly disagree with the quantitative parameter. A history of
ongoing or repeat violations could also be "high" based upon the
severity of the issue and the operators responses or this could be "low"
if the past corrective actions have been resolved and are not likely to
occur. A corrective action involving groundwater or landfill gas issues
could easily be an ongoing/repeat violation since resolving the issue
takes time.
- The control/mitigation comment of engineering design is very broad
and needs to be expanded.
Engineering Controls
- How does site specific design alternatives factor into the
controls/mitigations? For example, a monolithic final cover design might
be more appropriate than a conservative full vegetative one in desert
areas where water to maintain the cover is scare and contributes to
potential groundwater issues.
- Final, intermediate, and daily cover can have an influence on
environmental risk.
Mary Pitto
Regulatory Program Director
Regional Council of Rural Counties
(916) 447-4806
Task 6, Step 2 Home
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