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CIWMB’s Solid Waste Information System (SWIS) number: 23-AA-0021
Site Information per
Landfill Facility Compliance Study (Task 2)
Information Source: Owner/Operator—Mendocino County and the City of
Willits
Telephone conversation: April 19, 2004
The City of Willits and Mendocino County share ownership of the site;
the following summary reflects the telephone conversation with the
owner’s representative from the Willits.
Since the beginning of the study period (January 1, 1998), the owners
have not been required to conduct a corrective action program (CAP) or
been issued a water-related cleanup and abatement order (CAO). The
interviewee indicated that there have been no groundwater protection
measures beyond the regulatory minimums implemented at the site.
There have been no landfill gas (LFG)- or surface water-related problems
at this site since the beginning of the study period (January 1, 1998).
No gas- or surface water-related protection measures beyond the
regulatory minimums have been implemented at the site.
The interviewee indicated that the corrective action financial assurance
requirements of Title 27 of the California Code of Regulations (27 CCR),
“Article 5,”† have been overly costly without providing increased
protection of the environment at the site. As a result of requirements
in Title 27, Article 5, the owner spent approximately $50,000 to conduct
a study to devise a plan for responding to reasonable foreseeable
releases from the landfill and to hypothesize about what corrective
actions could be taken in the event of these releases. The anticipated
scenario involved a pump-and-treat system for volatile organic compounds
(VOC) in groundwater. Such a corrective action would involve around
$500,000 to implement. To assure adequate funding in the event of a
release, the owners established a trust fund in 1995. Considering that
the landfill has been in operation since 1969, and, to date, no
corrective action has been required, the likelihood of something new
occurring appears small. Setting aside such a large fund prevents
funding of other critical projects for a small municipality like
Willits.
Since the final cover construction was completed, the quality of surface
water coming off the landfill has been very high. Since there has been
no formal closure approval by either the regional water quality control
board (RWQCB) or the California Integrated Waste Management Board
(CIWMB) in this regard, the owners are still required to comply with the
site’s National Pollutant Discharge Elimination System (NPDES) permit
requirements.
During the time when the landfill was operating, the owner noted that
compliance with the State minimum standards for daily cover was very
difficult in the winter. The enforcement agency (EA) issued many
violations for daily cover during these periods. The difficulty arose
because of the high precipitation at this site and the difficulty of
placing saturated mud as daily cover. For a time, the owners attempted
using tarps as an alternative daily cover (ADC). However, the owners
discontinued the use of the tarps after finding that the 50 to 60 black
bears that frequently visited the site would either displace or damage
the tarps. During the dry periods of the year, the site was in
compliance.
Information Source: North Coast Regional Water Quality Control Board
Telephone conversation: April 9, 2004
E-mail response: May 6, 2004
This site is closed and capped. Since the beginning of the study period
(January 1, 1998), the owners have not been required to conduct a CAP,
nor have they been issued a water-related CAO.
Due to the owners’ limited resources, groundwater monitoring reports
have often been late and have consisted of raw laboratory data. The
owners are currently in violation of the site’s waste discharge
requirements (WDR) for reporting issues. The owners have been verbally
informed of the violation and, to date, have not taken steps to correct
the violation. The RWQCB is currently preparing written notice to the
owners regarding the violation and will enforce by formal order if
necessary.
Enforcement of the groundwater quality regulations is dependent on the
owners’ complying with the reporting requirements. The North Coast
Region’s limited land disposal program resources only allow for a
general review of the reports for completeness, accuracy, and
recognition of any issues. The RWQCB does not have the resources to
perform the statistical monitoring for sites that fail to perform their
own statistical monitoring.
Information Source: Enforcement Agency—Mendocino County Environmental
Health Department
Telephone conversation: April 9, 2004
There have been no landfill gas- or surface water-related problems at
this site since the beginning of the study period (January 1, 1998). No
gas- or surface water-related protection measures beyond the regulatory
minimums have been implemented, and none of the regulations have proven
to be overly difficult, costly, or confusing to implement at this site.
Information Source: Mendocino County Air Quality Management District
The Mendocino County Air Quality Management District (AQMD) has not
issued any permits, requested monitoring and reporting, conducted any
inspections, or issued any violations for this site. As such, the
Mendocino County AQMD was not initially contacted, but was later
contacted several times for review and comment of the in-depth
information as it was being developed.
†“Article
5” refers to “Article 5. Water Quality Monitoring and Response Programs for
Waste Management Units,” found in 23 CCR. Article 5 was later replaced by
Article 1 of Subchapter 3 of 27 CCR (“Article 1. SWRCB—Water Quality
Monitoring and Response Programs for Solid Waste Management Units”).
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