Landfill Facility Compliance Study

Bieber Disposal Facility: In-Depth Information

Information Source: Owner/Operator: Lassen Regional Solid Waste Management Authority
Telephone conversation: April 6, 2004

The landfill was closed using a geosynthetic clay liner (GCL) final cover in fall 2000. This type of cap was selected for the cover because there was no economical clay borrow source available. The owner has been conducting a detection monitoring program (DMP) since the beginning of the study period (January 1, 1998). Following placement of the cover, there was a detection of 1,2 dichloroethene at 0.92 micrograms per liter in one groundwater monitoring well. In response, the owner submitted and received RWQCB approval for an investigation work plan. In accordance with the work plan, six soil borings will be drilled to bedrock by May 1, 2004, and the owner will be submitting the findings to the RWQCB by June 15, 2004. Methane has also been detected at the property boundary in a sample collected from a groundwater monitoring well.

There are no other issues or concerns with respect to regulations and enforcement at the site related to air quality, landfill gas, or surface water.

Information Source: Central Valley Regional Water Quality Control Board
Telephone conversation: April 8, 2004

The groundwater is shallow and discontinuous at this site, and the hydrogeologic conditions are complex. The owner is conducting a DMP. There has been one monitoring well (MW-1) with elevated general mineral content and low concentrations of some organic constituents. Historically, the detections have been consistent for several quarters, then disappear, then return again. The owner asserts that the detections originate from the adjacent mill property (MW-1 is closest to this mill property). The owner is currently in the process of conducting an investigation that includes onsite soil borings to further evaluate the cause of the detections. The owner has tried to get permission to complete soil borings on the adjacent mill property; however, the mill owner has declared bankruptcy and the bank that now controls the property has denied access for this evaluation.

Although the investigation is proceeding, the site has not been placed in an evaluation monitoring program (EMP). The process of going from a DMP to an EMP was found to be too burdensome, and the owner has complied with the RWQCB’s requests to conduct further investigations. At present, amending the report of waste discharge (ROWD) and issuing revised waste discharge requirements (WDR) within the timeframe required by regulations in Title 27 of the California Code of Regulations (27 CCR) are impractical at this site, given the limited resources of both the owner and the RWQCB.

The rigorous statistical analyses required by the regulations for assessing groundwater monitoring data has been too difficult to enforce at this site. The Bieber Disposal Facility is typical of many older sites—the number of wells and their locations do not lend themselves to the statistical analyses required by the regulations. Trend analyses are more practical at sites like this one.

Information Source: Enforcement Agency—Lassen County Health Department
E-mail response: April 5, 2004

Since the beginning of the study period (January 1, 1998), the enforcement agency (EA) has issued areas of concern (AOC) for gas control, initially as a result of methane detection in a groundwater monitoring well. Quarterly follow-up with bar hole punches on and around the landfill, as well as off-site, are indicating that most of the methane is coming from stockpiled wood waste from the adjoining mill, disposed of at or adjacent to the landfill property. Investigations continue at the site to identify the source of methane, along with some additional groundwater investigations to clarify and verify some potential groundwater issues.

The experience from this site demonstrates that the regulations do not take into account the source of migrating gases, and they do not make provisions for sources other than municipal solid waste or the landfill itself.

No additional gas control, leachate control, drainage and erosion control, or surface water-related protection measures have been implemented at this site beyond the regulatory minimums. The interviewee noted that gas related regulations are more specific during the closure period than the operations period.

Since the beginning of the study period (January 1, 1998), there have been no AOCs, violations, or enforcement actions related to leachate control (27 CCR, section 20790) or drainage and erosion control (27 CCR, section 20820). However, it appears that there may be some surface water/leachate control issues (such as tannins/lignin) from the adjacent wood waste site.

Information Source: Lassen County Air Pollution Control District

Lassen County APCD does not have permitting, monitoring, reporting, or inspection oversight of this facility. As such, Lassen County APCD was not initially contacted, but was later contacted several times for review and comment of the in-depth information as it was being developed.

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Last updated: November 08, 2007