HomeMy WebLinkAbout1992-04-28 - AGENDA REPORTS - FED LEGISLATION (2)NEW BUSINESS
DATE:
SUBJECT:
DEPARTMENT:
BACKGROUND
AGENDA REPORT
April.28, 1992
Federal Legislation
City Council
City Mans r Approva
Item to be presented by:
Mayor Klaiic
Congressman Howard Berman (D -26 -Panorama City) is currently considering
legislation to facilitate the exchange of Angeles National Forest property, most
notably Elsmere Canyon, through legislative rather than administrative means.
The United States Forest Service (USFS), has. the authority to exchange .lands
within its ownership for other properties provided that specified environmental
criteria are met. The exchange process can be accomplished through legislative
means possibly including, but not necessarily requiring the same constraints as
the administrative process. Conversely, depending upon the specific legislative
language, more stringent requirements could be placed into a legislative
exchange than exist through administrative action.
On April 15, 1992, Congressman Berman met with Mayor Klajic, the City Manager
and the Intergovernmental Relations Officer to conceptually outline the factors
he is weighing before making a final decision on ,whether or not to sponsor
legislation. He expects to make a final decision about proceeding, -with the
legislation only after conducting a series of meetings with and recel ving input
from constituents, environmental groups and other affected parti s, including
the City of Santa Clarita.
Mayor Klajic indicated to the Congressman that due to far reaching implications
of the potential legislative proposal that she would like to discuss it more
fully with the City Council. The Mayor will be presenting in greater detail the
various issues discussed with Congressman Berman.
RECOMMENDATION
Receive Mayor's report, discuss and provide direction to staff.
MPM:229
l
ELSMERE CANYON: HOW MUCH DO WE R
Elsmere Canyon Is projected to be a 190 million ton, Class III, Urban Landfill. The
siting of a Hazardous Waste landfill adjacent to an active seismic fault would be a
violation of Federal Law. This sldn , on a creek bed that drains Into our valley and
replenishes our ground water supply, could also be a violation or the Safe Drinking
Water and Toxic Enforcement Act of 1988 (Prop. 85). The Environmental Impact Report,
contracted through the U. S. Forest Service, was due for review In the summer of 1991.
It Is now scheduled for mid-1992. The Los Angeles Regional Water Quality Control
Board will not consider the potential for groundwater contamination until the area is
reviewed In an Environmental Impact Report.
Those are some of the facts, but what are the real issues surrounding the siting of
this dump? There are dramatic environmental and financial consequences connected
with this multi -billion dollar trash heapl Elsmere is being designed as a Class III Urban
Landfill that can accommodate "Low -Grade" Nuclear Waste. The supporters of this
project will say, "This Is state-of-the-art technology." What they really mean is their
previous designs have failed, so they have anew' idea for this project I hope this is
not the same type of plan that m used at their Hazardous Waste Landfill and Leachate
Treatment Plant In West Covina, Ca.
According to a State of California Department of Health Services Repor dated
December 7 1990, BKK Corporation (Elsmere Corporation) has not resolved 2u
violations of Hazardous Waste Statutes and regulations, at their West Covina facility'.
Our recent late December rains caused 'material'to flow out of this dump and Into the
Woodside Shopping Center. Thls'state-o -the-art' Class III dump contained toxic
material. This tonic material took the paint off Christmas decorations, and the operators
refused to comment What will flow out of Elsmere into our neighborhoods?
In order for the'proposed' landfill to be located In Elsmere Canyon, It Is
necessary for the U. S. Forest Service to trade 2,000 acres of the Angeles National
Forest for 2,000 acres held in option by the Trust for Public Lands (TPL), a non-profit
corporation that purchases open and undeveloped land to be held untlf a public agency
can repurchase the land for park lands and open space. A letter 1 received from TPL
states, "a proposal Is pending to convey Elsmere Canyon involvingg a land exchange
through an Intermediary private corporation (BKK) Into the ownershipof the City prior
tothesale of to the Citttyye&'The Countyact that of L.A. snot ill n keeping with ththis e statedinto
TPL practice of
holding lands until they can be resold to public agencies for park lands & open space.
TPL further states If Elsmere Is determined not to be suited for a landfill, the exchange
WILL NOT take place. They further 'advocate' that all actions concerning Elsmere be
conducted openly, with Informed decislon-making.
Let's take an'open' look at the Incredible amount of money Involved In this public
benefit, and determine who really benefits. BKK Corp. will purchase 2,000 acres of the
Angeles National Forest, develop a "state-of-the-art" dump, and sell it to the City &
County of L. A. Joint Powers Agency (JPA) for 125 mililon,dollars.
The JPA will then lease or sell the dump back to BKK to operate. Using a
conservative figure or $30.00 a ton for waste disposal, BKK figures to gross over $.5.7
BILLION DOLLARSI Is this a fair trade for 2,000 acres of Forest land? I don't think so.
Will the U. S. Forest Service receive 6 billion dollars of land In exchange from TPL?
Besides a Hazardous Waste dump, what Is the 'public benefit ?
A little known policy of landfill operators is a practice called "Hosting Fees". This
is another way of saying enticement Hosting fees are montes paid to the "host" agency
of a dump site in this o JPA, for the privilege of siting a dump in their lurlsdictlon.
For example, tete County of Riverside regularly requires $7.00 per ion for ' hosting fees".
Using this fee schedule, the JPA would receive approximately $1.3 Billion Dollars to site
a dump within a mile of our City Limits and they offered the City of Santa Clarlta 7 cents
a ton as compensation. Seven centsl This is totally outrageous and ludicrous. I don't
believe the citizens of our dry can be bought as easily as the City & County of L. A., for
any price. The safety of our families and the protection of our quality of life and the
environment has Importance to us.
Those who support this dump have accused the City of Santa Ciarita of being a
"NIMBY" (Not In My Backyard) and act like Its some sort of immoral concept Is it
Immoral to have questions about this hazardous waste dump when there are still
reasonable doubts and reservations about our safety? Besides, we are not being any
more cautious about this dump than the insurance Industry, which, as a whole, refuses
to Issue Insurance policies to companies dealing with chemicals or chemical waste.
Are we to assume risks that the Insurance Industry won't touch? If the Insurance
Industry won't protect us, and the operator has not exhibited a willingness to provide
required financial Information, who will protect us? The Joint Powers Agency?
A recent California Supreme Court Decision now grants local governments
authority to regulate toxic waste dumps whose pollution violates local land -use laws
and permits. The JPA could mandate how the defilement created by the Elsmere
Canyon dump must be cleaned up In the future. The same agency that Is receiving 31+
billion dollars In "hosting fees". Who is protecting us? Don't we deserve protection
against environmental disaster? Why does It seem that money Is the driving factor of
governmental policy, and not the people?
Now Is the time to take action. Please take the time to write a letter, or make a
call and ask some very pointed questlons. Why Is the Trust for Public Lands making a
trace, of leassser value, to build a dump and not a parnd not gk? Why is the U. Sp Forest Service
on? Who
will this ump from any eny our forest for a vironmental tragedy Why r andarast e ourmelectedtloMdals
(County State & National) not taking a stronger stand against this potentially disastrous
projeciV When did BKK suddenly become responsible In landfill construction
operation? Where Is this staggering amount of money going and who really benefits?
CA.; The U. S. Department of In.
Send our letters &comments to: The Trust for Public Lands, an .
CA.; The U. Y. F TheS(yty & 6�tY ° dScA � Angeles'
The Los Angeles County Sa
Washington, DC, ed oftldal Yon can think of. flake them aware that the City
District and exert elect round for landfill techndogy, nor will we condone
Santa Ciarita will not be a testing ground an Cid ada e, but follow the
mion�of d you will see who
real benefits, and rs NOT the e•
Lee, Schramlingl r Place
19851 W �dplpe Plac
Santa Ciarlta,
(905) 298-9665
b'ebruary $6;1992
Ms. Nancy Carder
Depart&efit &Health Services
Toxic Substances Control Program
1408 N San Fernando Blvd.] Suite SW
Burbank, California 91604
Re: Recent rain damage
Dear Ms. Carder,
I appredate your recent call in response to my letter of December at, M91,
and your positive response to bur concerns.
I am taking this occasion to write yogi on separate, but potentially more
serious, matter cau�sed by the recent February rains. That is the damage caused by
the rains acid the hazardous materials that were spilled from the landfills in Los
Angeles County.
Members of our local Canyons Preservation. Committee and The Sierra Club
observed material being washed across roadways from Sunshine Canyon landfill.
A gray sludge -like material can still be observed running down the slopes
Sunshine Canyon. This causes its great concern over the safety of the lanIn
our county.
We know the damage caused by the December rains to the BHB landfill in
West Covina, and I fear that these latest rains have caused more damage. I am
respectfully requesting you and ybur agency hispect the landfills in Los Angeles
County fbr any possible damage and the discharge of hazardous; harmful and toxic
materials caused by the erosion of the landfill sites. I truly believe there was more
damage done to Sunshine and West Covina and possibly others. We need your
agOall know therto be e (mss no such thinctito and g as landfill; nhe pub9c from the �i one thaers of twillspills.ese forever
safe from Mother Nature.
Again, I thank you for your valuable assistance, your time and attention to
my request, and if I may be of any further help to you or your agency, please do not
hesitate to call upon me.
Sincerely yours,
J
Ms. Nancy Carder
Department of Health Services
Toxic Substances Control Program
1408 N San Fernando Blvd., Suite 800
Burbank, California 91604
Re: BKK Corporation
Letter dated Dec. 7,1980
Dear Ms. Carder,
I recently contacted your office to obtain information an the progress
being made on the written certification that the 28 violations contained in your
letter have been. corrected. I was told that the certification has not been
submitted, but that the 4awyers were working on the language."
BKK Corporation, under the name of Ebimere Corporation, is in the
process of designing a Class III Urban Landfill for Elsmere Canyon. This site is 1
mile outside the City Limits of Santa Clarita. This proposed siting is in
partnership with a Joint Powers Agency (City & County of Los Angeles) and
others. The Environmental Impact Report Is due for review in May of 1992
I have grave concerns for the safety of the citizens of the City of Santa
Clarita and our groundwater supplies, which lie beneath this proposed siting. I
am further concerned by the recent news that possible Toxic Materials were.
released from their West Covina facility by the recent rains (Dec 28 & 29 and
flowed in the form of mud and sludge into the Woodside Shopping Center,
adjacent to their site.
I would appreciate your assurance that the required corrections will be
made by BKK Corporation, and I would request that your stated re-inspecticm
take place to verify compliance and to insure that that area is not subject to
further toxic discharge. I would acates are lso
appreciate your understanding as to what
type of band Is rreequiredd turance oo protect communities that have landfills operators,
as neiwhat ghbors. of
I appreciate your time and attention to my request, and if I may be of any
assistance to you or your agency, please do not hesitate to call upon me.
Sincerely yours,
z, •
t>.n }.'C.>.Mw.J.�w .V MVL, �tY♦~ .... - HC+.t dl.f Yflu. •0...
ac►AirLitkfi.of NtAttN �Vlcit
toxic lresuMcu e0ar10i u rH"M b
of PCs"..
wN bultvMp fca+t!tb
.ta.c. u asw
n u� w,>000
Cater 7, 1990.
trr. laic, Hear
Ift
2210 kmm
Fest C mini, 0% 91792
Lima r )fir. ism
IV.,Xzc 44K
On Ooiaber 17, 18, 19 ars! 221 1990, PM=Y Clrrder, Tito imbarscn (ptveorat
OCtaber 1t!, 19; And 22; 1990)1 Car18 lbeilin=n (preaent oetc6er 18 arrd 19,
1990)0 016r -Orman (present October 17 Wid 22; 1990). Klan Souter (pcvsac:t
etaber
oit jird, 1a, 1090), Arid 7VQM p=Ai (present o -tuber 17, 1990)
rftst* ' ndr"' end tee Treatmentd p WTP- lousAn 1td at cin Of 21Sauth An=
jtvtnblr Mwt CbViras; C ilitOrnih 91792 (MA ID No. caoo 7786749) .
ircEiOtry. violaticrs of hazazio4s iv_aate. statutes
and _
Zt:o cilia vlolitia}ii and reVired aarz:etiva actiaLs ase listed bales.
i�ailuz*: to wrreCt the identified violatiarsl within the adwade pruww*d
re dt in the bap3riment citing The BM CQrpOr&tiCn for
CCIn iruirg/AddItional vialeticrd.
2 • VICTLeTiCltS:
s it tiaelth and safety fie, ChAPtsr 6.5; section 25189.2(c).
Stat disposed .of hazirdam wastes tt an unauthorized point st= it
faiisd td isdirrtAih the integrity of the clans I landfill cep as
part of tba tpg calleaUd, syslai aatmirq the rnleeas of landfill
gays to the Ate.
health ars! Saftty Cbdey Chftptar 6.51 section 25189.2(c).
BM di%==d of hazardaw i+asrtsl at An unauthorized point ubm. it
di9mt=lWd taste all onto the soil on the rrortlreast side or Ctrs
waste oil tank, &rid disdhargod all !rote the pug sill Onto the Soil
dirSctly rrntlf or thi =11=-orr bin tair arm.
COM : Titld 22, Ch1. cads of flogs. aeetiat 67104(c).
Mr. Jake Amar
Page 2
pecerber 7, 1990
b m did rout remedy cracks in the Class I Landfill cap in a tion.
schedule V.iaich ensures that the problem- does rat lead to an
envirorr ental and human health hazard.
.COLM 4: Title 22, Gal. Code of Regs.; section 67418(c)(2).
WK did.,txrt mdintdin the integrity.uld effectiveness
cover of +,1A Clb" I I&odfill by failing to repair
repair many cracks and .!doles foal on the 1040, 940
Rapes there Vas a significant rslsase of landfill gas.
C= :. Title 22; Cal. code of Regs.i section 67418(e)(2).
BM did not r ir"in the integrity and effectiveness
over of the class I Landfill by tailing to repair
repair two &reds of significant 0.6dideno6. one
area
the &orn end of the 1040 dock And the other bni
level At the sd thwest drain of the 940 deck
inadog:ats drainage.
de
Q= : Title 22, Cal. Coof Paegs., section 67418(6)(2)
of the. final
or ada4litaly
and 740 decks
of the .final
or adequately
inthabeing rices
ng the ground
Wb there is
BFK did;not ineinWn tie integrity and effectiveness of the final
cover of the Class I Landfill by failing. to repair the sdutherri
_..� ......_..,._,._.-_., slop�s_below the 940 deck that, l�txri.eci__evidenca of Pic pe..sepasntim.
dery Tftle 22; 'Cal. bode, of i*i. i sactiah 67d18(0) (2) .
SM did not maintain the integrity and effectiveness of the final
coverof the class I Landfill by failing to repair two areas of
significant arvaigii. Cana being an A aouthwost slope below the 1040
deck and thA other being on an Bast slope near intersection "8"
above the Nogilas axtensien road.
aWNi'-8: Tit1E 22, Cali Cade of Dass.; se=dan 67418(*) (1).
Em did not imaintain the integrity and effectiveness. of the final
ower of the Class I.lardfilli at specified in the approved cicv e
plane by having the following deficiencies in the laplementaticn of
the irrigitiort plan, iiddeq=ts irrigation resulting in areas too
dry that etre subject to dryness esnckS And instability of soil due
to ladk.of a VagetatiVe covert inadiquato irrigation and sprinklar
and pipd leaks restating in arias too Veit where water omad hither
peraolate into the landfill Lasts material; or pores and amus
M*Sidenod:
CCLW90 Title 22, Cal: Mde of Reqs., section 67418(a)(1).
Mr. Jake Amar
Page 3
December 7, 1990
Bial did not maintain tho integrity and 'effeetivvnosa of the final
ower of the class I 'arrlfill, an specified in the approved closure
plan, by having the Yellowing deficiencies in the implementation of
the landscaping plan: two arms where there is a significant
Amount of dead plant material reaulting in a fuel build ,up (one
area included two large piles of dead tumblewwds on the southeast
end of the 940 dk* and a'latVt area of dead shrubs on the sarthern
slopes . below the 940 deck) ► two species of native trees (iridian
tobacco And willow) that have been allowed. to grow throug hcut the
entire landfill and which hawi damp enough root system to damage
the cap as well as alla/ water to paroolata.into the larafill wasta
}.,tenial.
AUNT l0: Title 22, Cal. Code of Regs., section 67418(c)(5) and (a)(4).
MSX failed to adequately maintain the four permanent surveyed
benduearks in th! class I Landfill. They were not easily located
and had no permanknt identification or coordinates on them:
=?r 11: Title 22, cal. Code of. Regs.e section 67103 (b)(2)(B).
BW failed to have a means to c=pletely control entry to the
entire landfill faciiity..'ihe main entry gate at Azusa Avenue is
left cern mrd. unattended during business hours and than is an
t: Ted -road that passes between the main offics-ard"thd plight
sffitioH'14idre unauthorized tntryi could omhr.
�1t7I' 12: Title 22, Cal. Code of Re95., secti.cn 67015.
= has not established ani dwcmtrated to the Departme-it
financial assurancd for past -closure care of the Class I Landfill.
CMW 13: Title 22e MI. ckxle of Rags.; slctiEn 67243(a).
W stored tithe following oxhtairnars of )azardcus waste open iAm
not in use: ono =11 -off bin containing hazardous waste filter oaks
and six 5 -gallon pails ctnthining hazardous waste imc3ata at the
Leac3hatd Treatment Plant) two 5 -gallon pails cathtaining hazardous
wastb 1&cthata at the liac hats collection statim directly above
e* icwe nara ititiont two 55-ga11m drum. and two split
polyethylen3 drtwd,of bxisitd oil in the waste oil tank aria:
mC41P 14: Title 22, Cal. Code of Regi.y sectsah 66508 (a) (2) (3) (c) .
SM failed to label had memo: aoam dation start dates on the
following containam .holding hirardous waste, Thraa roll -'off bins
cr*Aini q hazards d vasty filter cake, and six 5 -gallon palls
M
8larrtt hazardcUs vast, lehdats at the iaadmta Treatment
-gallm pails containing hazardous waste lead -Ate at
Mr. Jake Amar
Page 4
Decmrbar 7, 1990
f:
the
el dachata collection statim directly abava the alawer'; tlarq
waste _oil in the waste of drum and O flit polyethlerie dims of
9MMLM: Title 22, Cal. Code of Pegs., eectirn 67124.
BM failed to maintain the required aisle space for nine 55 -gallon
drums amtainirg.Waste oil in the waste oil tank area.
V23 -L15: Title 22, Cal. Code of Rs3s.; section 66508 (a)(3).
Stat failed to mark the following hazardous Wasthe words Waste" or te storage tanks with
waste oil tank, zse for the MW type of identification: the
wase hold french drain system, the Nogales
erg tank, and the green lsac2mte transfer tank at the
lower flare station.
ZAHL12: Title 22► Cal' -Code of Pegs., aectiClh 67120 (a).
BW did not raintain its facility in a manner to prevent a release
of hazardc= waste to. air, soil and surface water which could
threaten human health and the anvir=wnt when it allowed the
relaaw of off gas condensate from a leak at the c=xlensata dre
port at the Leachate Treatment_ -Plant►: _ �_..... ._ .
3 Title 22; Cal. Codi Pegs,, section 67104 (a)(b).
Batt failed tolrtspOc+t its tdadhate Treatment Plant for maltcatctions
and detarIOrati 'p operator & Mrs and discharges which mcxad a
reliese of offVali CcthdenGate resulting in an enviturmsnW and
)UMn health hazard. §tQC tailid to follow, a written ec$a1<hle for
inspMUIV, the
; x8tin4 dad struequipmental equipment at the I.erhateTIvatzbenk .
X12: Tit" 22, Cal. Code of Regs.# 8GCticn 67104 (d).
BM tailed to P'vdaod WGAJiy ittepecUch logs for the cpiliaUM' and
b;MIinspe"yammL
�Ulxu Aptl*hhil ota1989 6thd1 of T190 trot the data of Plant for thJA
19
NW -failed to tocotd and date ransdial actions to problem listed
bn -fhe follcwirg stlt-Cant33ned t3raathirg Apparatus
intpecticti logs ddEM, 11/13/890 3/22/90, 4/25/90, and 7/17/90)
SML24: Title 22, Cal: Code of R67a.; section 67252 (b)(2) and Oapnrtaiatt
of Health Serv'am Hazardous Waste Taeility Permit for the =L"fill leacihats Treatment Plant dated June 30, 1987 Section
IIL13.3.b.
v
Ar. Jaki Amer
PaN S
Decanber 7, 1990
BM operated the uncovered clarifier tank in the Lsacihate Trvat:ten
Plant vith a freeboard level of 17 1/2 inches iMtM4 of the
required 24 incus of stated in the Deparbw-nt's permit.
CCMT 21: Dement of fisalth Services Hazardous Waste facility Permit for
the EM Landfill Leachate Treatment Plant dated Jura 30, 1987
section 111.B.l.M
am operated eight hazardous waste storage tanks (six influent and
two effluent tanks) at the reax:3hate Treatment. Plant that were not
marked with the internationally r9=1nized hazard identification
A�ssaoci tionas �iro�iirred bey the Dopartmm:t National by the permit
ire Prr4ention
MIE 22: Approved Operation Plan for the BM Landfill Leachate Treat:as:t
Plant, section vii 1.
BF failed to poet a sign warning "Not for Drinking Water Purposes"
on the one million gallon reservoir and its two auxiliary tanks
used for the filling of water trucks,as wall as the valve on the
4 -inch main at the leachate Treatment Plant. All of which contain
treated leadhats that is used for irrigation and dust control.
COUNT 23: Title 22, Cal: Mdi Of Rags., section 67002 (b) and (d).
MM has not submitted to the Departmant their amml adjusted
closure snot' estimate for tha Leachate Tteatment Plant for 1988,
1989 and 1990. BM Gadd not produce a copy of the 1990 adjusted
closure cost estimjte by the final data of this inspection.
aCiM 24: -Title 22, Cal. Code of Rags., section 67126.
M7 failed to make emergency response arrargwxtts with local
authorities, for both the Claes I Landfill, and the taac3hats
Timatmnt Plant.
CI T1. 25: Title 22, Cal. Cotte Of Rage., section 67164 (a).
BRR failed to make available for inspection the Part A applications
for, botch, the CUM I Landfill and the Leachate Treatment Plant.
=Jirr 262 b'e�t of PAJIth Siitvices Hazardous Wast. Facility Porbit for
the BM Landfill Leachate Treatment Plant dated June 30, 1987
section II.J.
Bm did not make the arvnhal Waste Minimization Certification for
the Lead -At! T%*atment Plant as required by the Dsparhwit's
permit.
ok
t. c
Hr- uake Amar
per 7, 1990
m[3NP 27: Title 22, Cal. Code Of Regs., section 67164 (a) -
En failed to make wMilabld for inspection wmual repot and/or
mwdfast cmpies for asbestos disposal at the Class III Landfill -
of of Health Services Hazardous Waste facility permit for
the BiQC Landfill Lead -Ate Treatment Plant dated June 30i 1987
section II.a.S.b.
En !ailed to cmVly with the California "icral Water Quality
Control Board's order Ho. 88-390
Waste to prDischarge
�YF sf=
'rements f=
Shredder' Watto Disposal, by failing
lab romps that must be sent prior to the disposal of sect' load
and kept for the last 3 years. These lab results must Certify that
the heavy metals in the waste is below hazardous IwQla; so that it.
can be disposed Of at the Class III Landfill.
1. Corrbct violations upon r000ipt of this report.
Please submit written certification ahic' contains the lasx3uage in Title 221
Cal. code Regs.j Section 66373 (d), to this office by January 7; 1991 that
the above violations have boon corrected.
The pcparbwnt will' c=xk=t. a reinsPectia' of -HM to verify caspliarrd:
L1,e iss,r.,�. of this Report of Violation Arid schedule for ccrpliance does not
preclude the t from taking administrative, civil, or crl+t+lrHl action
ad a result of the violations toted herein-
If
you havo any. q.MtjcM r8Tardin4 this. report, ply contact Nancy Carder
at (81a) 667-3061.
certified !Sail
84820
R R R
cc: see next page
sincer'el`y,
t7nit Chia!
Facility Hw-Agement Branch
Supervisor MichaelAntomovich
BOARD OF SUPERVISORS
Room 889, Hall of Administration
500 West Temple Street
Los Angeles, CA 90012
Dear Supervisor Antonovich,
II was pleased to have received your letter, dated December 19, 1991,
indicating your Interest in my November 23,1991 letter to Mr. Charles Carry. I
still have had no other response to my letter, as I mentioned during our January
13, IM meeting.
I realize that Mr. Carry must be very busy, but I feel that I. should have
received a response sooner than the four months I have waited. I have the
uneasy feeling that his response to my letter Is being delayed. I can come to no
other conclusion, for the lack of cooperation from the Department of Sanitation.
During the recent rains in February there was an extensive amount of
erosion to the Sunshine landfill. Largequantities of debris and sludge was seen
spilling across roadways. This is similar
to the damage that occurred to the
Bll$ West Covina site In December, 1991. I have written the State Depart ent of
Health Services and asked that an inspection be made of all the landfillm
landfills L A
County. I believe that there may be a potential health hazard from these
'sanitary' landfills, and the protectiom.of our citizens requires the constant
monitoring of these landfills by health officials.
I would appreciate your asking Mr. Carry if he could possibly respond to
letter and relieve my misgivi'ngs. If I could be of any further assisstance, I would
make myself available at anytime.
Respectfully yours, ;
Lee Schramhng
19861 W Sandpiper Place
Santa Clarita, CA 91821
(806) 298-9885.
ttr� of �5ujjer1jtsVxs
C90tuttv of Ps '
MICHAEL D. ANTONOVICH
SUPERVISOR FIFTH DISTRICT
December 19, 1991
Mr. Lee Schramling
19851 West Sandpiper Place
Santa Clarita, California 91321
Dear Mr. Schramling:
Thank you for the copy of your recent letter to the Sanitation
Districts asking that you be notified of public hearings and
expressing your concerns regarding the possible elimination of
the public hearings for the Puente Hills Landfill and other
planed landfills.
I have asked Mr. Charles Carry, the Chief Engineer and General
Manager of the Sanitation Districts, to forward me a copy of his
response to you.
Mr. Carry will be in contact with you.shortly.
Sinc rely,
MICHAEL D. ANTONOVICH
Supervisor, Fifth District
MDA:cdv
refltr/doc _-
cc: Mr. Charles Carry
xe's:a 'tZ.0; �3
ROOM s69. HALL OF ADMINISTRATION. 500 WEST TEMPLE STREET. LOS ANGELES. CA 90012 • TELEPHONE (213) 974.5555
(213) 974.1010 (FAX) ••
LEE SCHRAMLING
19851 W Sandpiper Place
Santa Clarita, CA 91321
November 23, 1991
LOS ANGELES COUNTY SANITATION DISTRICTS
1955 Workman Mill Road
Whittier, CA 90601-9998
ATTN: Mr. Charles W. Carry
Chief Engineer S General Manager
Dear Mr. Carry,
It has come to my attention, that in the name of expediency, you
wish to eliminate the Public Comment Period for the Puente Hills
landfill expansion EIR and for the final Environmental Impact Report
on the Integrated Waste Management Program for Towsley, Blind and
Mission/Rustic/Sullivan planned landfills.
In my estimation, this would be in direct violation to the
California Integrated Waste Management Act of 1989 (AB939). In order
to fully understand the scope of your intended actions, I wish to -be
furnished with a copy of the approved Los Angeles County Integrated
Waste Management Plan, per Chapter 7, Article 1 (Section 91800). In
the event.your plan has not yet been approved, I would like a copy of
your authority to expand any existing facility, per Section 50000 of
the Public Resources Code (AB2296), and a projected approval date for
your plan, including what objections were raised and how you intend to
mitigate them.
Until the public has been satisfied that your agency has complied
with the California Integrated Waste Management Act of 1989, and sub-
sequent amendments, I believe that all public hearings, required by
law, should be held. The public, whom you serve, has the right and
the opportunity to be heard.on these issues. No public agency has'the
authority to circumvent the will of the people or the law of the State
of California.
I request notification of the public hearings, previously
mentioned, and I will await delivery of copies of your approved Integ-
rated Waste -Management Plans.
Sincerely yours,
Lee Schramling
cc: Los Angeles County Board of Supervisors
LEE SCHRAMLING
19851 W Sandpiper Place
Santa Clarita, CA 91321
The Trust for Public Land November 20, 1991
116 New Montgomery, 3rd Floor
San Francisco, -CA 94105
ATTN: Mr. Martin J Rosen, President
Dear Mr. Rosen,
I wish to bring to your attention a matter of great concern to
the members of my community. Your firm, with a reputation for pre-
serving undeveloped lands for parklands and open spaces, will be a
leader in the development of a Class III Urban Landfill. I refer to
your association with BKK Corporation'of Torrance, Calif., and the
development of Elsmere Canyon into a landfill.
I am enclosing a copy of the latest list of Environmental vio-
lations committed by BKK Corporation at their West Covina Treatment
Plant. According to the State Department of Health Services, these
charges are still pending and the Certification of Correction has not
been completed. The citizens of Santa Clarita are puzzled by your
apparent support for the degradation of -our pristine canyons, and the
almost certain contamination of our water supplies. This, in all
probability, would be in violation of the Safe Drinking Water and
Toxic Enforcement Act of 1986', Chapter 6.6 (Section 25249.5).
The siting of this landfill, with a design for the dumping of
'Low Grade' Nuclear Waste, adjacent to active seismic faults would
also be a violation of Federal Law.
I request .that your firm reconsider its decision to abandon a
policy of protecting the environment and, for whatever remuneration,
proceed with a plan to assist in the destruction of our environment.
I am certain that there will be significant public expression to
challenge this destructive alliance and it will be noted by the U. S.
Forest Service and the Department of the Interior. I have also ob-
served a negative perception by our City Council for the SantaClaraRiver Project because of your participation in Elsmere Canyon and the
proposed landfill.
I would be available for any positive discussion on this issue
and will await,.your; hopefully, prompt reply.
Si a y, rs,
Le chramling
J
M
ATTN: Mr. Ronald Stewart
Regional Forester
Dear Mr. Stewart,
I would like this opportunity to express the dismay and.aban_
donment being felt throughout my community caused by the actions of
the United States Forest Service. I am referring, of course;_to the
partnership between the United States Forest Service and-BKK.Corpora-
tion of Torrance; Ca. Your agency will be a major component in the
development of a potentially toxic landfill in Elsmere Canyon: „
It is incomprehensible to me, and others in my city, hots an
agency of the United States Government, with a edict to preseive our
forests, can ignore this responsibility. I know you must be aware
that this landfill site has been engineered to accommodate 'Low Giade'
Nuclear Waste. You must also be aware that this siting could violate
the California Safe Drinking Water and Toxic Enforcement Act of 1986,.
Chapter 6.6 (Section 25249.5). Federal Law would prohibit siting:a
landfill adjacent to an active seismic fault.
I am enclosing the latest list of Environmental violations
committed by BKK Corporation, this time at their West Covina Treatment
Plant, According to the state Department of Health Services, these 28
violations have not been mitigated, nor has a Certification -of Correc-
tion been issued. The lawyers are still working on the °language!';
and the matter is still pending. I am quite sure this.matter will not
go 'quietlyO away.
I request that your agency reconsider its decision to abandon a
Policy of -protecting our National Forests and, for whatever.renumer
ation, continue to ignore the pleas of the citizens you are bound to
serve. I am certain that there will be significant public expression
to challenge this destructive alliance, and it will surely be noted by'
many of our elected officials. I do not believe that the United
States Forest Service should be in the Landfill Business; especially
with a.partner-, who, for profit; destroys our environment.
I would welcome the opportunity to discuss this matter further
and I will await your, hopefully, prompt reply.
Sincerely yours,
Lee Schramling € a wigs=.
:g
.
4
LEE SCHRAMLING
19851 W Sandpiper Place
Santa Clarita, CA 91321
s
UNITED STATES FOREST SERVICE
November 2 8.141
4
Western Regional office
p
%
630 Sansome Street, # 559
'
San Francisco, CA 94111
ATTN: Mr. Ronald Stewart
Regional Forester
Dear Mr. Stewart,
I would like this opportunity to express the dismay and.aban_
donment being felt throughout my community caused by the actions of
the United States Forest Service. I am referring, of course;_to the
partnership between the United States Forest Service and-BKK.Corpora-
tion of Torrance; Ca. Your agency will be a major component in the
development of a potentially toxic landfill in Elsmere Canyon: „
It is incomprehensible to me, and others in my city, hots an
agency of the United States Government, with a edict to preseive our
forests, can ignore this responsibility. I know you must be aware
that this landfill site has been engineered to accommodate 'Low Giade'
Nuclear Waste. You must also be aware that this siting could violate
the California Safe Drinking Water and Toxic Enforcement Act of 1986,.
Chapter 6.6 (Section 25249.5). Federal Law would prohibit siting:a
landfill adjacent to an active seismic fault.
I am enclosing the latest list of Environmental violations
committed by BKK Corporation, this time at their West Covina Treatment
Plant, According to the state Department of Health Services, these 28
violations have not been mitigated, nor has a Certification -of Correc-
tion been issued. The lawyers are still working on the °language!';
and the matter is still pending. I am quite sure this.matter will not
go 'quietlyO away.
I request that your agency reconsider its decision to abandon a
Policy of -protecting our National Forests and, for whatever.renumer
ation, continue to ignore the pleas of the citizens you are bound to
serve. I am certain that there will be significant public expression
to challenge this destructive alliance, and it will surely be noted by'
many of our elected officials. I do not believe that the United
States Forest Service should be in the Landfill Business; especially
with a.partner-, who, for profit; destroys our environment.
I would welcome the opportunity to discuss this matter further
and I will await your, hopefully, prompt reply.
Sincerely yours,
Lee Schramling € a wigs=.
:g
.
4
":9Erivironmefttai" ry
CITIZENS -FcY du ?JE7 -riZ oxv1pow,"oN%
.1.11. office. (.A13)
Leaking Landfills
In San Fernando Valley
A new CBE report takes a close look at the threat leaking
landfills pose to underground drinking water supplies in the
San Fernando Valley groundwater basin, and at the
government's failure to thoroughly investigate that threat.
by Michael Kent
In July CBE released a new
report entitled, "Leaking Landfills
in San Fernando a e ." The pur-
pose ort -Fe report was to document
the threat the over 60 active and
unerl 'n th r Land -
i s ave generally been known
to cause the toxic contamination
of groundwater, even those like
the ones in the valley that have
never been permitted to accept
hazardous waste.
CBE researcher Michael Kent
found that toxic organic chemicals
have been discovered in nine valley
landfills. Because of inadequate
data, however, he could not deter-
mine conclusively if these chemicals
are finding their way into the
groundwater basin.
Kent also found that major lhves-
tigations underway at the Sheldon -
Arleta and Bradley landfills that
could throw valuable light on -the
connection between landfills and
groundwater contamination in the
valley are failing to probe fully into
the scope of toxic chemical leakage
from these landfills.
CBE undertook the landfill inves-
tigation becnuse efforts by regula-
tory agencies to determine the
various sources of toxic chemicals
polluting the valley's groundwater
.Michael hent is a Research A.ssociare
('Br'..- Stitt Franciarn otlire.
basin, a major source of Los Angeles
drinking water and a federal Super -
fund site because of its extensive
contamination, have been moving
extremely slow. Groundwater moni-
toring wells near four of the 'valley's
landfills have been known t6 con-
tdin toxic organic chemicals since
the early 1980s. yet it wasn't until
this year, under a program estab-
1lished by the state legislature in
1584, that any of the landfills in the
valley underwent a thorough inves-
tigation to determine if they might
be contaminating groundwater.
Because of the importance of this
state piograca it became a primary
focus of CBE's report.
The 1984 legislation called for
150 investigations (called Soli --
Waste Assessment or
S) to be performed statewide
each year. The investigations were
to be conducted by the landfill own-
ers or operators and then reviewed
by the appropriate Regional Water
Quality Control Board. The nine
Regional Water Boards were re-
quired to determine which landfills
in their respective districts would
be investigated by the established
deadlines.
The Los Angeles Regional Water
Board ordered that four landfills in
the San Fernando Vallev--Sheldon
-Aricti.—Bradlev, Scholl Canyon -
and Mission Canvon—submit their
s to te agency by the first
year deadline of July 1, 1987. Thir-
teen other valley landfills were re- c)TffEl
quired to submi WATs by
e second ye
deadline of July 1,
1988. In all, sixty-three vol - G 3
fills wi su nn r Ts by the year ?'o%A
e ,os Angeles Water
Board will either approve the find-
ings of the reports and take appro-
priate action to clean up any con-
tamination identified or require
further investigation if they find
the SWAT to be inadequate.
' The finding of CBE's report that
the SWAT reports submitted by the
owners of the Sheldon -Arleta and
Bradley landfills were deficient has
important and far-reaching impli-
cations for the future success of
identifying groundwater contami-
nation caused by leaking landfills.
Given that not enough information
currently exists to determine the
impact toxics in landfills are baNing
on groundwater quality, the regula-
tory community is going to rely
completely on the SWAT progriam
to provide this infornintion. If the
SWAT program fails to work prop-
erly, the necessary information ill
always be lacking.
Deficiencies found by,CBl.' ir.:i:c
Sheldon-_liieta SWAT inched. J1 :eu
Y '
Toxic Chemicals Found If!
Bfadley Landfill Laachate
Highbst California Department
Chemical Concentration of Health Services
Found (ppb) Action Level
trichloroethylene 6
5
1,1-dichloroethane 84
20
1,2-dichloroethane 38
i
toluene 35
i 00
benzene 16
0.70
vinyl chloride 20
2
1,2-dichloropropane 30
10
chloroform 600
100 (t)
(1) Federal and state maximum contamirani level for total hihalomethanes
Source: SWAT Report, Bradley L in&11,, July 1, 1987, Leroy Crandall Associates
discussion of the potential degrada-
tion of water quality a9 the result of
gas migration, despite 'strong evi-.
deuce that such a problem may
exist; and the failure to analyzb
leachate found at the bottom of the
landfill far toxics, which, iffotihd,
would pose an extreme threat to
groundwater quality because the
landfill is unlined.
Deficiencies found in the Bradlev
tsce box above);
of the soil layer
s,ote ras or u•acnate mi¢ration.
There are two -main reasons the
S:4AT program is not working. The
first relates to the structure of the
v.❑ nm-
program as it was legislatively
mandated. Thi! legislation requires
A landfill owner or operator to in-
vestigate and report the results to
the Regional Board. The landfill
bwners or bperators tydically hire
ebitsultirig Guns to perform the in-
vestigation of the landfill. Not sur-
prisingly; as was the case for both'
the BradPey and Sheldon -Arleta
landfills, these consulting firms are
requested to do the minimum inves-
tigation necessary to fulfill the re-
quirements of the law. After all,
their clients, the landfill owners,
would be indicting themselves if a
thorough investigation determined
that their landfills were contami-
nating groundwater.
The second reason the progn-ant is
Crilin„ i, that the supposed check to
=.Flnrironmet�tal: 77
the system, that of regulatory over-
sight, is woefully inadequate. The
Regional Board staff is required to
review a SWAT proposal before an
intestfga5on begins and to review
the final report to ensure complete.
ness. As is often the case, the
Regional Board section charged
with overseeing the SWAT program
is severeiv understaffed. This only
allows them to spend a minimum
amount of time reviewing each
SWAT and puts a tremendous
amount cf pressure on them to
accept minimally acceptable or
unacceptable SWAT proposals and
final SWAT reports.
Because of the above considers
tions. CBE recommended in its
report that the Regional Board re-
ject the Sheldon -Arleta and Bradley
reports and require the landfill
owners tr resubmit the reports af-
ter urderaking the specific recom.
mendatiens made by CBE. CBE's
report air recommends that the
Regional Board be given enough
staff to adequately review each
SWAT. If these recommendations
are followed, these two SWATS will
not only provide a more accurate
picture of how these landfills are
affecting groundwater, but they
will also ensure that all of the
SWATS to be performed on valley
landfills in the future provide accu•
rate information.
CBE presented the results of its
study to the Regional Board at their
August board meeting. The board
was receptive to CBE's concerns
and promised to evaluate the
SWATS that have been submitted
and to respond by their Novernber
board mee ng to the recommenda-
tions mode in the CBE report. In
the mean.^' -.e, CBE ivilf continue to
alert a: c t•.d consumers and inter.
est;H.i'e;^si:.tors and rrnulr•.tor:
as tort -e �.:i+nisshortcoinin;. we
Gr: rd'n :.._ -M)rts to protea. a
m.gf.r L_.-..;;t•ir: arca dri•,::i-•_
October _;, 1991
Mayor Carl Boyer and
City Councilmembers
CITY OF SANTA CLARITA
23920 Valencia blvd.
Santa Clarita, CA 91355
Dear Mayor Boyer,
I am taking this opportunity to write to you about =.,i
issue that is of great importance to the citizens of our
community. That'issue, the siting of landfills in the
canyons that surround our city, is compounded by the latent
plans to use these "Urban Landfills" as a depository for
"Low Grade" Nuclear Waste.
I am certain that there are no members of The City
Council, nor any members of the City Staff, that would favor
such a possibility. I am also certain that there would be a
emotional public outcry from the citizens of our community
if they were cognizant that these landfills were being
designed for just such a possibility. The canyons surround-
ing our valley should NEVER be the dumping grounds for
Nuclear Waste, 'Lotp Grade' or otherwise, and it is incumbent
upon the officials of our city to prevent this from happen-
ing. Now.is the time to be proactive and not reactive; once
the waste is dumped, it will never be removed. A 'Love
Canal' must never be.allowed to or -cur again!
I, therefore, respectfully request that The City
Council of The City of Santa Clarita adopt a formal reso-
lution opposing the dumping.of ANY Nuclear Waste in ANY
Urban Landfills, specifically those in close proximity to
our City. Further, the Council should oppose the dumping of
nuclear waste in any landfills with the State of California.
This resolution should be forwarded to the State Senators
and Assemblypersons, who represent us, with the strongest
possible recommendation for Legislation prohibiting the
dumping of nuclear waste in 'Urban Landfills'. It is the
obligation of our elected lawmakers to protect the health
and welfare of their constituents. Please let our concerns
be known,_and take the lead in the protection of our valley
and its residents.
Re pec ully .ours,
Lee Schramling
19851 W Sandpiper ce
Santa Clarita, CA 91321
(805) 298-9665
D'PARrblEliT OF REALMa.*w.....o.,
toxic xr+U►+tCL co :FRYla
m �Ris+ort
b�
wrtaMu.rxor
s7 U7 Y f?. .7liD
Mr. Ja)m Amur
2210 Averse
Best Cavite, Ch 91792
On October 17, 18, 19 and 22, 1990,
October is. 19, and 22, 1990). Carla .Eaillr�as�,, Tian �r'rn (prega=
1990), filar_ `brMn (present October 17 and 22 igg0�� October lH.ard 19,
0r*L�ber 17 and -IS'
1990) r and Q1ppn+y g� ) r t O i�yrgZt
this Dg=t�nt, cortiucte4 an (Present October 17, 1990)
Nanta landfill and leachate Treab meat pyo located at D�ticn of 210 South
Arma
xvwm, list CbYirn, California 91792 (FM =p M. C RD0677s6749) .
ri a result of that in�irn, violaticrs of hazardous waste statutes and
The specific viOlaticne and reVired curzstctive actiara art listed belay,
will in
Failure lc ect to identified violatims within the eggprevented
c XI iMti Wadditionl vio7a� t �C3T� The EM Corporation far
2: Health and safety Lode, Ck+pter 6.5, section 25329.2(c).
@OC disposed of hazardoiv watts at an unauthorized Point ken it
tailed to saintain the integrity of the Class Z Iardfill cap as
part of the gas collectia7 aystad c mitg the rnleesa of landfillgases to the atsnaphere.
=IT 2: Health and Safety Gude, ChRPtQr 6.5, section 2s1a9.2(e).
B disposme of hazard aa Warta at an tmthoriyed paint. +tan it
di'ate all arta the soil on the nvrthenst side ,of
the
wants oil tank, and disc ar7 d oil flus the
4Lrectly 1'ct of tta roll -Orr bin storage area. mill �� the aOj�
MM -3: Title 22, Cal. CYtie of )lags. section 67104 (c) .
Mr. Jake Amer
Page 2
Ueceuber 7, 1990
Biot did not remedy cracks in the Class I Landfill cap in a time.
sctxxh le which ensures that the problem does not lead. to an
en:virorresntal arra h=3n health hazard.
CC= g: Title 22, Cal. Code of Reqs., section 67419(c)(2).
BRK did not maintain the integrity and effectiveness of the fiscal
cover of the Class I.I�andfill by failing to repair or -adequately
reir many cracks and holes faced cn the 1040, 940. and 740 decks
ase there was a significant release of landfill gas.
Q= g: Title 220 Cal. Code of Reqs., section 67418(e)(2).
Biot did not maintain the integrity and effectiveness of the final
cover of the plass I Landfill by failing to repair or adequately
repair two areas of significant subsidence. one Asea being across
the southern and of the 1040 dock and the other being the ground
level at the southwest drain of the 940 deck where there is
inadequate drainage.
SOLS: Title 22, Cal. Code of Reqs., section 67418(c)(2)
Biot did not maintain the integrity and effectiveness of the final
cover of the Class I Landfill by failing to repair the southern
slopes below the 940 deck that showed evidence of_slcpe separation.
CQUNT3: Title 22, Cal. Code of Reqs., section 67418(c)(2).
EFK did not maintain the integrity and effectiveness of the final
ower of the Class I Landfill by failing to repair two areas of
significant erosion. one being on a sont2 went slope below the 1040
deck and the other being on an east slope near intersectirsn "8"
above the Nogales axtermicn road.
57—: Title 22, Cal, Cade of Rags., section 67418(*)(1).
= did not maintain the integrity and effectiveness of the final
cover of the Class I Landfill,. as specified in the approved closure
plan, by having the following deficiencies in the implementation of
the irrigation plan: inadequate irrigation resulting in .seas too
dry that are subject to dryness cracks and instability of soil due
to lack of a vegetative covert inadequate irrigation and sprinkler
and pipe leaks resulting in areas too wet where voter could either
percolate into the landfill waste material, or prd and cmuse
subsidence.
SOLS: Title 22, Cal. Code of Reqs., section 67418(e)(1).
Hr. Jake Amar
Page 3
DQcertxr 7, 1990
BXK did not maintain the integrity and effectiveness of -the firal
cover of. the Class I TA fill, as specified in the approved closure
Plan, by having the following daficianaies.in the isplementation of
the landscaping Plan: two areas Mv-s a there is a significant
amount of dead plant material resulting in a fuel build up (one
area included two large piles of dead t=blsweeds on the southeast
end of the 940 deck and a large arena of dead shrubs on the southern
slopes below the 940 deck); two species of native tress (indian
tobacco and willow) that have been allowed to grow throughout the
entire landfill and which nava deep enough =opt systems to damage
the cap as well as allow water to percolate into the larv+fill wasta
:.dtarial.
7T 10: Title 22, Cal. Code of Rags., section 67418(c)(5) and (d)(4).
Bids failed to adequately maintain the four permanent surveyed
benchmarks In the Class I Landfill. They were not easily located
and had no permanent identification or coordinates on them.
Q= 11: Title 22, Cal. Code of Regs., section 67103 (b)(2)(B).
W failed to have a means to caspletely control entry to the
entire landfill facility. The main entry gate at Azusa Avenue is
left open and unattended during business hours and theta is an
Unguarded road that passes between, the main office and- the weight
station where unauthorized entry could omit.
47UNI 12: Title 22, Cal. Coda of Rugs., section 67015.
Bid{ has not established and damxwtrated to the Departcant
financial assurance for post -closure care of the Class I Landfill.
STM'' '• Title 22, Cal. Cede of Regg., section 67243(a). ;
Bim( stored the following ccntainazs of hazardous waste open when
not in use: one roll -off bin containing hazardous waste filter cake
and 8iX 5 -gaper pails containing hazardass waste leachate at the
1"chats Treatment Plant; two 5 -gallon pails containing hazardous
waste leachate at the leachate collection statim directly above
the- laws; flans statim; two 55 -gallon dnms .and two split
polyethylene drums of waste oil in the waste oil tank area.
== 14: Title 220 Cdl. Luis of Regs.w section 66508 (a) (2) (3) (c).
BiaC failed to label. and mark accumulation start dates on the
following containers, hon hazardous
o4hta ha»,••••,a � waste: Three roll -off bins
-- waste filter cake, and six 5 -gallon pails
hazardous waste lenchata at the Leachate Treatment
Plant; two 5-9allon pails arntaininq hazardous waste leadhata at
Jr. JaJca Amer
Fh9a 4
CeCr 7, 1990
the loachata collection station directly above the lower .flare
-station; nine 55-931lon dams and two splitye dnmu of
waste oil in the waste oil tank area, poi thlene
ZUZ,U: Title 22, Cal. C:de of Reqs., Mien 67124.
WX failed a
dim �htainin7toawasteintain .oilthe ir; waste oil tank area.
� aisle space for nine
tLl�: 55yallan
�Title 22, Ch1. Clyde of Reqs,, sectio'; 66508 (a) (3).
BM failed to mrk the following hazardous waste storage tonic: with
11 "Hazaxdcua Wagta" or my waste Oil tank, s� for the type of identification: the
leachate holding tank, and the ngreed leachate
trans �� tank at laor flare statie .
99M-11: Title 22, Cal, Code of Rogs,r aecthm 67120 (a).
Jaid{ did not naintain its facility in a manner to prevent a -release
of hazardous waste to air, soil a:'d surface water which could
threaten human health and the envirmnant when it allowed the
release of off gas condensate from a leak at the condensate. drtp
- - - port at the Imchata Treatment plant.._:_.:. ._
}i): Title 22, Cal. Cbda Regg•, section 67104 (a) (b) .
EM
and lCalled tats inspect its joachate Treatment Plant for malft=t1ons
release of oft '
goperator errors an=d discharges which =Wad
a
" fixate .,rrultirg .in an enviro
human health hazard. MW failed to follow a wwrittenc &.jul and
inepacting the operating and styrol �lg„ent at lsedsata
Tx'eattaa�nE Plant.
AH 19; Title 22, Cbl. Code of Re93., section 67104 (d).
Jade failed to produ= wajayindPactim 1
mitral equiRnent at the Laeclhnte Tte�a for the. cparatinq aryl
January. thrn April of 1989 and all of 1990 to- the f Plant for 19;
�+tcn.
BW failed to rvasrd and date ranedial actions to pstableag Bated
on the following salt -Contained gztathing pppratu9
inspection logs dated: 11/13/89, 3/22/90, 4/25/90, and 7/17/90)
x.29: Title 22, Cal. Code of Reqs section 67252 (b) (2) and DaFert>nant
Of Health sezvio9s Hazardous Warta Fbeili
Landfill teacate Treatment plant Plant dated t5' Permit for the 1ST
III.J3.3.b. Jeune 30, 1987 Section
Mr. Jake Amar
Page 5
Deownb6r 7, 1990
BKK operated the uncovered clarifier tank in the Leachekte Treatrant
Plant with a freeboard level of 17 1/2 inches instead of the
required 24 ihc3hes as stated in the Depot mentis permit.
OOM 2 : Department of Bealth Services Hazardous Waste Facility Permit for
the BM 'Landfill Leachate Troatment Plant dated Jura 30, 1987
Section III.S.l.d.
Mat operated eight hazardous wastes storage tanks (six influent and
two effluent tanks) at the Leachate Treatment Plant that were not
marked with the internationally recognized hazard identification
syetei placards developed by the. National Fisc Prevention
Association, as required by the Department's permit.
CItW 22: Approved Cperaticn Plan for the EKK Landfill leachate Treatmen
Plaint, section VII F.
En failed to peat a sign warning "Hot for Drink m Water Purposes"
on the one million gallon reservoir and its two auxiliary tanks
used for the filling of water trucks, as well as the valve on the
4 -inch main at the Leachate Treatment Plant. All of which contain
treated leachate that is used for irrigation and dust control.
C=?r 23: Title 22, Cal. Code of Rags., section 67002 (b) and (d).
MM has not submitted to the Department their annual adjusted
closure c,7st estimate for the Leachate Treatment Plant for 1988,
1989 and 1990. SM could not produce a copy of the 1990 adjusted
closure cost estirata by the final dais of this inspection.
Q= 24: Title 22, Cal. Crde of Rep., section 67126.
BM failed to make emergency response arrangements with local
authorities for both the Class I Landfill, and the Isachate
Treatment Plant.
CaM 250 Title 22, Cal. Mde of Regs., section 67164 (a).
M failed to make available for inspection the Part A applications
for, both, the Class I Landfill and the Lsachate Treatment Plant. -
CM= 2 : Department of Health Services Hazardous Waste Facility Permit for
the EM Landfill Leachate TZeatment Plant dated June 30, 1987
section II.J.
EM did not make the. annual Waste Minimization Certification for
the Leachate Treatment Plant as required by the Department's
permit.
Mr. Jaka Umar
Page 6
Domer 7, 1990
CaM 27: Title 22, Cal. CLMde of Regg•, section 67164 (a).
nn failed to make available for in Pection annual reports amVor
manifest copies for asbestos disposal at the Class III Landfill'
DMartimit of Health Services Hazatdc= Haste Facility Permit for
tha BM Landfill Lsachatg Treatment plant dated Jame 30, 1987
section II.G.l.b.
BICC failed to caxcply with the California Regional Hater QnalitY
Control Board's 0td6r No. 88-39: Haste Discharge Requirements for
shredder waste Disposal, by failing to produce any shr'eddar waste
lab results that must be sent prior to the disposal of each loed
and kept for the last 3 yeats. These lab resents must certify that
the heavy metals in the waste is below hazardous levels, so that it
can be disposed of at the Class III Landfill.
1. correct violations upon roonipt of this `Port*
please submit written certification which contains the lamylage in Title 22,
Cal. Cede Regs., Section 66373 (d), to this office by.January 71 1991 that
the, above violations have been corrected.
The Departtrent will conduct a xeinsPection of EKC to verify c=.pliance.
The issua a of this Report of Violation and schedule for Coipliance does not
preclude the Depart =t fzsrn taking administrative, civil, or criminal action
as a res%tlt of the violations noted herein.
If. you have any questions regarding this reper't. please contact Nancy Carder
at (818) 367-3051.
sinceree�ly,
tease ncu��
[Mit chief
Facility HW%&9emeMt Brarrh
Certified Mail
84820
R R R
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