CIWMB’s Solid Waste Information System (SWIS) number: 19-AR-0008
Site Information per
Landfill Facility Compliance Study (Task 2)Information Source: Owner/Operator
(Waste Management)
E-mail responses: April 15, 2004, April 20, 2004, and May 12, 2004
The owner indicated that the site is implementing a corrective action
under a detection monitoring program (DMP) due to volatile organic
compound (VOC) impacts to groundwater in down-gradient wells from
landfill gas. The owner determined that the VOC problem was due to the
entrance of landfill gas (LFG) into groundwater well casings with
subsequent diffusion into groundwater within the well. Action levels
have been established for specific VOCs; concentrations of these VOCs
remain below the action levels. The owner indicated that upgrades to the
gas system at the facility have aided in the substantial decrease of
VOCs in groundwater. The owner indicated that VOCs are generally on the
decline coincident with LFG collection system upgrades. The owner
indicated that the VOC concentrations remain below action levels.
The owner stated that on four occasions between November 24, 2003,
and January 6, 2004, the EA measured LFG in one or more perimeter probes
above 5 percent as methane. On January 13, 2004, the CIWMB issued a
notice of intent (NOI) to list on its Inventory of Sites Violating State
Minimum Standards. The EA followed with a notice of violation (NOV) for
these boundary probe exceedances on January 28, 2004. To address the
boundary probe exceedances, the owner submitted a remedial action plan
and has implemented all measures contained in the plan. The owner
curtailed LFG migration to the perimeter probes by adding and replacing
LFG collection wells, upgrading the LFG headers, producing increased
vacuum to the LFG collection system, and establishing a gas well
dewatering system. On April 29, 2004, the CIWMB issued a letter
rescinding the NOI and acknowledging correction of the gas violation.
According to the owner, the Bradley Landfill has not been issued an
area of concern (AOC) or a violation for leachate control, or been
subject to enforcement actions for drainage or erosion control. At
Bradley, engineered best management practices (BMP) divert surface water
drainage to an on-site stormwater basin, thereby minimizing off-site
stormwater discharge.
There have been no surface emissions NOVs during the study timeframe.
One notice to comply (NTC) was issued on May 28, 2003, for emissions
from the base of two LFG extraction wells. The two wells were
reconnected to the LFG collection system and additional soil was placed
around the base of each well.
Other violations during 2002 included one for odor due to a break in
an LFG condensate line and two for odors from the trash operation. The
owner replaced a broken condensate valve to fix the condensate leak and
addressed the trash odors by moving the active tipping area away from
the outside slopes. An odor study was contracted to a consulting firm to
study the variables that account for odors in the area surrounding the
landfill and to provide meteorological data that will assist in planning
odor-producing activities at the site. The owner performs bi-monthly
surface monitoring at the LFG collection wells in addition the monthly
surface monitoring required by the South Coast Air Quality Management
District (SCAQMD).
Information Source: Los Angeles Regional Water Quality Control Board
Telephone conversation: March 26, 2004
The regional water quality control board (RWQCB) stated that the site
is under a corrective action program (CAP) due to an LFG release from
the unlined Bradley East Landfill. The RWQCB indicated that the owner
installed an enhanced LFG extraction system that includes LFG collection
wells and headers, and which helps the owner to meet requirements
contained in the CAP.
Information Source: Enforcement Agency (City of Los Angeles Department
of Environmental Affairs)
E-mail response: April 7, 2004
The EA reported that the landfill received a notice and order on May
24, 2001, for explosive gas control, but the owner corrected the
problem. Two inspection violations occurred in June 2002 and the owner
brought the site into compliance. An NOV was issued on January 28, 2004,
and still stands because a March 18, 2004, violation went against the
NOV condition that the site be in consistent compliance for 90 days from
the date of the NOV.
The CIWMB issued an NOI for repeated violations of explosive gas
concentrations at the property boundary. The EA indicated that to its
knowledge, the site was not placed on the inventory list. The EA
indicated that the owner has implemented two LFG remediation plans to
correct the explosive gas concentration exceedances. The plans include
construction of additional LFG collection wells and headers to increase
the system’s capacity to control LFG.
The EA indicated that the site has not received an AOC or violation
for surface water-related issues.
Information Source: South Coast Air Quality Management District
Telephone conversation: March 31, 2004
E-mail response: April 28, 2004
The South Coast Air Quality Management District (SCAQMD) indicated
that the landfill operator has been issued an NTC for LFG surface
emissions and NOVs for nuisance violations. The SCAQMD reported that the
landfill owner redrilled LFG collection wells and installed a new LFG
flare to address the violations.
Bradley Landfill was subject to a variance by the SCAQMD Hearing
Board for Rules 203 and 1150.1 for surface emissions, from June 2000
through April 2001. The owner was issued an NOV on May 31, 2001, for
violation of Rule 1150.1 for surface emissions. The owner was subject to
a stipulated order for abatement from the SCAQMD Hearing Board for Rule
1150.1 for surface emissions from July 2000 through February 2002. The
three NOVs issued in September 2002 and November 2002 were for nuisance
trash odors from the working face; one of these NOVs also included odors
from a condensate leak.
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