CIWMB’s Solid Waste Information System (SWIS) number: 16-AA-0009
Site Information per
Landfill Facility Compliance Study (Task 2)Information Source: Owner/Operator—Kings Waste and Recycling
Authority
E-mail response: April 5, 2004
The first documented groundwater release at the site occurred in 1988.
The old Hanford site is 90 acres and the landfill is a closed, unlined
facility. The release included constituents normally found in older
sites. According to the owner, after 16 years and four regional water
quality control board (RWQCB) representatives, the Fresno RWQCB agreed
to the corrective action plan on or around March 22, 2004. The owner
stated that at times during the process, the RWQCB has taken up to 10 to
12 months to answer some of the correspondence.
The site is adjacent to three dairies that may also be polluting
groundwater, but no regulatory action has been taken against these
adjacent sites. The owner has found that regulatory action is dependent
on the specific RWQCB, and that based on experience with multiple sites
located in various regions, the owner has found that the approach is not
uniform.
The site had methane detections above the acceptable 5 percent level,
for which it received violations. In response, the owner installed a
landfill gas collection system consisting of 42 extraction wells and a
flare. There have been no problems implementing the existing landfill
gas-related environmental protection regulations at the site. The owner
stated that he had no additional input regarding surface water issues or
air quality issues.
Information Source: Regional Water Quality Control Board, Central Valley
Region
Telephone conversation: April 2, 2004
E-mail response: April 16, 2004
The RWQCB has recently finished its review of the third draft of the
proposed corrective action program (CAP), and has issued its approval.
The unlined landfill leaked, resulting in volatile organic compounds
(VOC) in groundwater which are likely attributable to landfill gas.
There is also some presence of inorganics in groundwater, which
indicates a possible leachate presence.
The primary corrective action will be to pump and treat groundwater in
the vicinity of the down-gradient edge of the unit. There have been some
smaller hits of VOCs further down-gradient from the waste management
unit’s western Point of Compliance. There will be a trial period allowed
to observe whether these down-gradient VOCs will naturally attenuate. If
VOCs are still detected after four years, then the owner will have to
propose a solution for remediating groundwater beyond the existing
extraction well system.
Natural attenuation generally results in diluting and dispersing the
waste constituent, not removing it. Many dischargers want to use natural
attenuation and test periods. The interviewee stated that his preference
is to do whatever is reasonable and possible to clean up the site. The
interviewee believes that Title 27 of the California Code of Regulations
(27 CCR) is not specific as to whether or not natural attenuation is an
appropriate method for groundwater remediation. This lack of specificity
allows some flexibility in implementing the regulations. However, the
wording in the regulations requires removal of contaminants from
groundwater. This wording conflicts with many approved CAPs that are in
effect these days. Until the results from the test of natural
attenuation are in at this site, the RWQCB won’t be able to assess the
success of the CAP. If the CAP is successful, it sets a standard for
other sites to look at. If the CAP is not successful, alternative
correction action measures will have to be implemented. Results from the
test program will provide a knowledge base for the future.
In many cases, the regulations provide more tools than are necessary and
afford the RWQCB strong enforcement powers. However, the time frames
specified in 27 CCR, such as 90 days to complete an evaluation
monitoring program assessment, are unrealistic, resulting in the
issuance of notices and violations that impact both regulators and
dischargers.
Information Source: Enforcement Agency—Kings County,
Division of Environmental Health Services
E-mail responses: April 6, 2004 and April 19, 2004
During the study period (January 1, 1998, to December 31, 2001) facility
inspection reports identified areas of concern (AOC) in August 1998, May
2000, July 2000, and August 2000. These were due to gas being present at
concentration levels above regulatory limits at the property boundary.
In between the specified months, numerous routine inspections revealed
the presence of methane gas at greater than regulatory limits at
property boundaries for which violations ensued.
Before the beginning of the study period (January 1, 1998), the facility
was identified as being continuously in violation of explosive gas
threshold at the property boundary. Amended Stipulated Notice and Order
#98-01 (ASN&O #98-01) was issued to the facility. This notice and order
superseded Stipulated Notice and Order #96-01 (SN&O #96-01) that related
directly to a landfill methane gas violation at the property boundary.
In addition to requiring the preparation and implementation of a
landfill gas remediation plan, ASN&O #98-01 also mandated a closure date
of October 31, 1998 for the facility along with updates of the facility
closure and post-closure maintenance plans.
The facility operator, Kings Waste and Recycling Authority, complied
with ASN&O #98-01. On July 31, 1998, the EA received a landfill gas
remediation plan prepared by the operator's consultant that included
design information on a gas collection and flare system. A copy of the
plan was also submitted to the CIWMB.
The gas collection and flare system was completed in January 2000 and
start-up followed shortly thereafter. The landfill gas collection and
flare system is currently working successfully in extracting methane gas
and its presence has no longer been documented as either a violation or
as an AOC.
The proper design and installation of a gas collection system is
essential at landfills. In the case of the Hanford Landfill, surface gas
piping was installed with expansion joints. An insufficient number of
expansion joints were installed within the system, resulting in damage
to the piping network during normal operations. The installation of
additional expansion joints to the existing system allowed the system to
function properly.
The EA believes that there are no prescriptive minimum requirements that
were not implemented by the owner that could have reduced or eliminated
the landfill gas problem at the Hanford Landfill during the period it
was open for business.
The Hanford Landfill employed an engineered alternative composite cover
system as opposed to a prescriptive standard clay cap. The EA believes
that the cap was installed properly. The interviewee indicated that
without a landfill gas extraction system, landfill caps force gas to the
boundaries and to the groundwater, but this phenomenon has not been
found to contribute to the site's gas-related problems.
The EA believes that the explosive gas standard at landfill property
boundary should include a variance for landfill sites where there are no
sensitive areas adjacent to the landfill property. Landfill gas is
monitored as a subsurface constituent at landfills, and not in ambient
air. Therefore, the EA’s opinion is that there is less of a hazard with
its presence at or above 5 percent in the oxygen-deficient subsurface
environment, as compared with its presence at the same concentration
level in air (ambient condition).
No landfill gas regulations are in place that inhibit the facility from
meeting gas control performance requirements. Existing landfill gas
regulations are appropriate for mitigation. The EA is not aware of any
landfill gas regulations that are overly difficult or costly without
protecting the environment, or too confusing (or contradictory) to be
implemented or enforced at this site.
Since the beginning of the study period (January 1, 1998) no AOCs or
violation reports have been issued to the owner of the landfill for
drainage or erosion issues. The Hanford Landfill cover design consists
of drainage swales feeding into a concrete lined culvert system around
the landfill footprint perimeter. This design has worked very
effectively in directing run-off and controlling erosion. The EA is
unaware of any surface water regulations that are overly difficult or
costly without protecting the environment, or that are too confusing (or
contradictory) to be implemented or enforced at this site.
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 (APCD) Regulation VIII (Fugitive Dust Prohibitions). The San
Joaquin Valley APCD stated that there have been no air quality-related
issues at Hanford Sanitary Landfill since the beginning of the study
period (January 1, 1998) and there have been no problems implementing
the existing landfill environmental protection regulations at the site.
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