CIWMB’s Solid Waste Information System (SWIS) number: 24-AA-0002
Site Information per
Landfill Facility Compliance Study database (Task 2)Information Source:
Owner/Operator (Merced County Solid Waste Division)
E-mail responses: April 7, 2004 and April 8, 2004
The owner stated that the site has not been required to conduct a
corrective action program (CAP) or come under a water-related cleanup
and abatement order (CAO) since the beginning of the study period
(January 1, 1998). There have been no problems implementing the existing
groundwater-related landfill environmental protection regulations at the
site.
The site has experienced subsurface landfill gas migration
approximately 10 feet beyond the property boundary in a small section of
the facility. The site was listed on the CIWMB’s inventory of facilities
that violate State minimum standards, for the gas migration issues. The
nearest residence is approximately one mile beyond the facility
boundary. As there was no existing buffer at this time, the Merced
County Department of Public Works purchased the neighboring property to
create a buffer zone. There has been no landfill gas migration beyond
the facility’s new property boundary, and the Billy Wright Disposal Site
came into compliance on January 8, 2001, when the new permit reflected
the boundary change. While the existing regulations allowed the landfill
gas migration issues at the site to be mitigated appropriately, the
owner stated that new proposed regulations do not allow land purchase as
mitigation for landfill gas violations, which was an effective method at
this site.
The owner stated that the site has not been issued any areas of
concern (AOC) or violations for leachate control or enforcement actions
for drainage/erosion control since the beginning of the study period
(January 1, 1998). There have been no problems implementing the existing
surface water-related landfill environmental protection regulations.
The owner stated that there have been no air quality-related notices
to comply (NTC) or notices of violation (NOV) since the beginning of the
study period (January 1, 1998). The owner stated that the San Joaquin
Valley Air Pollution Control District (SJVAPCD) standard to limit
visible dust emissions (VDE) to less than 20 percent opacity is
difficult to implement. The owner’s understanding is that the actual
opacity reading can only be determined by a certified opacity reader,
and that very few VDE sources have actual on-site certified opacity
readers due to: (1) course complexity, (2) expense, and (3) renewal
requirements for the certification process.
Information Source: Regional Water Quality Control Board, Central
Valley Region
E-mail response, April 8, 2004
The RWQCB stated that the site has not been required to conduct a CAP
or come under a water-related CAO since the beginning of the study
period (January 1, 1998), and there have been no problems implementing
the existing landfill environmental protection regulations.
Information Source: Enforcement Agency (Merced County Department of
Public Health
Division of Environmental Health)
Telephone conversation: March 31, 2004
E-mail response: April 15, 2004
The EA issued an enforcement action due to 5 percent methane
exceedance at the property boundary. The site was listed on the CIWMB’s
Inventory of Solid Waste Facilities Violating State Minimum Standards
after two consecutive months of non-compliance. The owner’s response was
to acquire additional property and extend the landfill gas monitoring
system to the new property boundary. While not considered a favorable
solution by some CIWMB Board Members, the additional buffer between the
waste boundary and the property boundary brought the site into
conformance with the regulations.
The EA has considered all aspects of the site in interpreting the
regulations. The site is an old unlined landfill in a rural environment
with no residential, commercial, or industrial uses nearby. The
groundwater below the site has no beneficial use. It was determined that
there were no impacts to vegetation as a result of landfill gas
migration, since there were no surface gas readings. The methane
exceedance was a violation, but it was not causing harm.
There have not been any surface water issues at the site and no
offsite discharges. Surface water drainage from the site flows into an
intermittent stream with 3 sampling points. Sampling is conducted
pursuant to the waste discharge requirements. The EA enforces leachate
control/drainage on the landfill face, but there is not much rainfall at
the site (12 inches per year). The biggest problem at the site is wind
and its effects on litter control.
Information Source: San Joaquin Valley Air Pollution Control District
E-mail response, April 6, 2004
Landfills must comply with the San Joaquin Valley Air Pollution
Control District’s (SJVAPCD) Regulation VIII (on fugitive dust
prohibitions). There have been no air quality-related issues at this
site since the beginning of the study period (January 1, 1998) and there
have been no problems implementing the existing landfill environmental
protection regulations at this site.
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