CIWMB’s Solid Waste Information System (SWIS) number: 07-AA-0032
Site Information per
Landfill Facility Compliance Study
(Task 2)Information Source: Owner/Operator—Keller Canyon Landfill Company
Telephone conversations: January 8, 2004 and April 7, 2004
With the exception of a violation for the late submittal of a Title V
report (air quality), there have been no environmental compliance issues
at this site since the beginning of the study period (January 1, 1998),
and there have been no problems implementing the existing environmental
regulations.
A few years prior to 2004, volatile organic compounds (VOC) were
found in the underdrain. It was concluded that there was landfill gas
migration from the leachate collection and removal system (LCRS) into
the underdrain via the liner anchor trench. The issue was properly
handled by the regulatory agencies through their interpretations of the
regulations.
This site has a large buffer area that has been helpful in protecting
human health and compliance with the perimeter gas monitoring
requirements. The minimum standards do not require such a large buffer;
however, this buffer may have contributed to Keller Canyon’s compliance
success. In addition, the owner takes a very aggressive stance on gas
control at this site. The owner expands the system every year, which
leads to better capture of the landfill gas and protection of the
environment. These actions are beyond the minimum requirements.
The owner emphasizes winterization and intermediate cover at Keller
Canyon. Intermediate cover is placed in layers thicker than 12 inches to
minimize the potential for daylighting waste. In addition, the owner has
used alternative daily cover (ADC) extensively, although not required by
the regulations. ADC is protective of the environment and conserves
resources.
Information Source: Regional Water Quality Control Board, San
Francisco Bay Region
Telephone conversations: December 12, 2003, April 2, 2004, and April 8, 2004
E-mail response: April 13, 2004
There have been no groundwater related compliance issues at Keller.
In early 1999, occasional VOCs were first detected in the underdrain.
These compounds, mainly chlorofluorocarbons (CFC) did not match the
typical VOCs found in the site's leachate or gas condensate, and are
believed to be the result of a spill during construction rather than a
release from the landfill. The level of the CFCs has diminished since
their first detection. More recently, there have been occasional
detections of benzene, toluene, ethylbenzene, and xzylene (BTEX) and
chlorinated hydrocarbons in the underdrain. Again, it appears that these
compounds are not a result of leachate release but are due to the
migration of landfill gas. In response, the landfill is stepping up the
rate of landfill gas extraction in newly constructed waste areas. The
VOC detections are now dropping, and the site therefore remains in
detection monitoring.
The groundwater monitoring system was developed with potential
groundwater use in mind. The groundwater in the vicinity of the site is
not intended for domestic use due to a high mineral content. Based on
the setting and location of the site (canyon), there are no up-gradient
sources that could impact groundwater and complicate the monitoring
process.
Information Source: Enforcement Agency (Contra Costa County Health
Services Department, Environmental Health Division)
E-mail response, April 8, 2004
The enforcement agency (EA) has not issued any gas-related areas of
concern (AOC) or violations to this site. There have been no problems
implementing the existing landfill gas-related regulations and there
have been no measures beyond the regulatory minimums that have provided
additional protection. However, gas wells are installed annually, as
necessary to control landfill gas. Keller Canyon has been attempting to
permit and construct modular power stations to convert the landfill gas
that is collected. This project has been in progress for several years.
There have been no surface water-related compliance issues, no
problems implementing the existing surface water-related regulations,
and no measures beyond the regulatory minimums that have provided
additional protection.
Information Source: Bay Area Air Quality Management District
Telephone conversation: April 5, 2004
The Bay Area Air Quality Management District (BAAQMD) issued one
notice of violation (NOV) on March 31, 2002, for late submission of the
semi-annual Title V report. The BAAQMD has found that this site has
generally had good compliance; the few issues encountered have been
resolved quickly, and there have been no problems implementing the
existing air quality regulations.
The BAAQMD uses the owner’s dust control program as an example in
developing permits for other sites. The owner’s program includes
requirements for paved roads, parking lots, sweeping, watering for dust
control twice daily, use of dust suppressants, and limits on vehicle
influx. These measures represent the best management technologies for
dust control that are currently available and are in line with current
regulations (but are not beyond the minimum requirements).
Interviewer’s Note: The current EA officer is new to
the position and was not able to provide substantial information regarding
the site. The comments were provided by the previous EA officer, who no
longer works for the Contra Costa EA.
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