Landfill Facility Compliance Study

Ballard Canyon Landfill: In-Depth Information

Information Source: Owner/Operator—Santa Barbara County
E-mail response: March 31, 2004

The site closed in 1969 and predated the existing prescriptive requirements for containment systems, so there were not any prescriptive requirements to implement at the time of closure. The groundwater problems were detected because the county moved forward with the original Solid Waste Assessment Test (SWAT) program when the regional water quality control board (RWQCB) was not requiring operators to continue with the original SWAT program. The cleanup and abatement order (CAO) came about because of impacts to groundwater from the former Ballard Canyon Landfill. Volatile organic compounds (VOC) were detected in groundwater monitoring wells and several nearby domestic wells.

As a corrective action, the county installed a landfill gas (LFG) collection and control system and a 60-millimeter cap over the landfill and improved drainage around the site to keep offsite water off the landfill. The LFG system was installed in 2001, and the cap was installed in 2002. The detection of VOCs has decreased since the corrective action measures were implemented. The LFG collection and control system consists of 16 wells with carbon treatment. The LFG produced at the site is of too low quality to flare.

A groundwater treatment system is scheduled for installation in April 2004. The project will consist of extraction, air stripping, and reinjection. The system is being installed to remove VOCs from groundwater as part of the site’s corrective action program.

A gas control AOC (required by Title 27 of the California Code of Regulations, section 20919) was issued in 1999 for perimeter probe readings exceeding 5 percent. As a result of the installation of the landfill gas control system in 2001, the gas probe readings have dropped below 5 percent.

There have been no surface water or air quality issues at the Ballard Canyon Landfill.

Information Source: Central Coast Regional Water Quality Control Board
Telephone conversation: April 6, 2004
E-mail response: April 14, 2004

Santa Barbara County leased the property and operated the site as a landfill from 1949 to 1969. In 1969, the county closed the landfill, installed a cover, and returned the site to the property owner. The cover consisted of a few feet of soil (no hydraulic conductivity requirement at that time). The owner sold the property to a developer, who in turn divided it into two parcels, and separately sold each for residential use.

Homes were constructed on the landfill site within approximately 100 feet of the waste limit, but not over waste. Because the area is rural, septic systems and groundwater wells were installed for each property.

In the early 1990s, Ballard Canyon was listed in the SWAT database that was used to identify leaking landfill sites. The site was ranked "Level 10," which indicated a low potential threat to water quality and reflected the site’s complexity. The regional water quality control board (RWQCB) had very little information on Ballard at the beginning of the SWAT, besides knowing where the site was located. As funding for SWAT investigations stopped when the process had addressed up to "Level 6," Ballard was not investigated. However, the regulations required that all sites comply with the SWAT reporting requirements (even though there was no budget for reviewing the investigation results). The RWQCB requested a proactive approach from the local landfill owners to comply with this regulation. The county was proactive with its sites, including Ballard Canyon, and in the late 1990s, local wells of various types were tested. It was found that Ballard Canyon may have impacted local wells with VOCs above maximum contaminant levels for drinking water.

Litigation began in response to groundwater impacts from the site. The county attempted to continue monitoring these impacts, but the litigation proceedings limited access to the property. The RWQCB issued a CAO, which compelled the property owners to grant access to the wells for monitoring, because the CAO required the county to monitor groundwater. The CAO also required installation of a gas collection system; installation of an engineered alternative high density polyethylene (HDPE) cover system (no CCL); development of a monitoring and reporting program; and an alternative water supply for the property owners. The CAO set a timeline for implementing the cleanup program.

The county installed a pump-and-treat groundwater extraction system, with the purpose of supplying the treated water to the property owners for their use. The property owners refused the treated water; one of the properties is a vineyard, and there was a concern regarding misperception of the impacts that treated groundwater could have on grape quality. Instead, a new well was drilled away from the site to supply the alternative water. At the time of this interview, the logistics of providing an alternative water supply to the property owners are still being worked out. Currently, the pump-and-treat system is idle. It has been proposed that the pump-and-treat system be used to treat and re-inject groundwater in a strategic cross-gradient location to direct groundwater toward the extraction wells and potentially accelerate the cleanup of the groundwater. The CIWMB has partially funded the corrective action at Ballard Canyon.

According to the RWQCB, the county has fulfilled all the conditions of the CAO. The interviewee expects that the CAO will be rescinded in the near future, and then the RWQCB will regulate the site solely under the general order for abandoned sites in the county (it is currently regulated under both the CAO and the general order). The general order will require that monitoring and reporting of groundwater continue.

The current monitoring and reporting program developed in response to the CAO has been revised at least once and is expected to be revised again this summer. The revisions have involved fine-tuning the monitoring program. The upcoming revision may remove wells from the monitoring program that have been categorized as "nondetect."

The interviewee indicated that landfill gas, as well as leachate, were the cause of impacts to groundwater. The RWQCB reached this conclusion based on the results of EA monitoring. Explosive gas was detected by the EA in gas monitoring probes at the site, indicating migration of landfill gases. As a result, the RWQCB required installation of a gas collection system as part of the corrective action for the site.

Existing regulations for groundwater-related issues at landfills have been working well at Ballard Canyon. While outside influences may complicate the regulatory process, addressing the concerns of all parties is also part of the process.

Information Source: Enforcement Agency—County of Santa Barbara, Public Health Department, Environmental Health Services Division
Telephone conversation: April 9, 2004
E-mail responses: April 13, 2004 and May 13, 2004

The EA issued a gas control-related area of concern (AOC) in 1999 to the owner for not completing quarterly reports. Litigation that had barred the owner access to the site resulted in the owner being unable to complete required monitoring. In addition, the EA was not able to conduct inspections between May and December 1999 for the same reason. The situation was corrected by March 2000. Gas levels have been a concern, but no violation of the 5 percent at the perimeter has been documented by the EA since 1996, when 5 percent methane was measured at the north side of the landfill. It should also be noted that the nearby residences are located south of the landfill.

The gas extraction system consists of 16 multidepth gas extraction wells, headers, a blower, and a biofilter and carbon filter treatment system. According to the owner, the carbon filter works better, and is used more frequently than the biofilter. In addition, passive injection wells have been installed to prevent gas migration. The owner installed the gas extraction system in response to gas-related impacts to groundwater as required by the RWQCB.

The owner installed an engineered final cover system at the end of 2002. During construction of the final cover, the gas extraction system was temporarily out of service, which resulted in some detections in the gas monitoring probes; the owner reported these detections. However, by the next inspection the problem had been corrected, and no violation was documented.

With respect to surface water issues, there have been a few AOCs associated with erosion control issues, but the owner has addressed them in a timely manner. There have been no leachate control-related compliance issues at the site.

There have been no problems implementing the existing gas-related and surface water-related regulations. There have been some difficulties implementing the regulatory process given the disruptions caused by litigation associated with the site. In addition to access restrictions noted above, there have been litigation-prompted studies including air monitoring and associated constituent analyses that were performed by the CIWMB and independent consultants at nearby residences. Some airborne VOCs were detected, but the studies were unable to conclude that the landfill was the source of the VOCs. Constituents found in the homes were those common to indoor air, and are emitted from such sources as mothballs and new carpeting.

Information Source: Santa Barbara County Air Pollution Control District
Telephone conversation: March 26, 2004
E-mail response: April 29, 2004

A gas control system was installed around 2001, at which time the air pollution control district (APCD) issued a permit for the system. The gas control system is simple and consists mainly of extraction wells and a biofilter-carbon filtration treatment system. No flare was installed.

During the months of May, June, and July 2003, the biofilter-carbon canister control system failed to achieve an overall non-methane organic compound (NMOC) control efficiency of 80 percent, as required by the APCD permit. A notice of violation is being issued for this period of noncompliance. The owner/operator told the APCD that they had been determining when to change out the carbon canisters by measuring the NMOC concentration between the canisters using a borrowed portable photoionization detector (PID), a procedure listed in their operations and maintenance plan for the control system. The PID results did not correlate to the results from the influent and effluent grab samples that were taken and analyzed by a certified laboratory every month. Compliance with the control efficiency requirement was achieved when the owner/operator changed out the carbon canisters on August 15, 2003. The owner/operator also eliminated the possibility of erroneous PID readings from future monitoring activities by deciding to use bag collection and lab analysis for the canister midpoint sampling.

The amount of excess emissions from the above noncompliant period was relatively small, due to the low magnitude of the emissions during normal operations within the site’s permitted limits and the fact that the control system was still functioning, but at a level below normal operational efficiency.

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Last updated: November 08, 2007