HomeMy WebLinkAbout1995-11-28 - AGENDA REPORTS - EIR CHIQUITA CYN LANDFILL (2)"Upletux[ ' 1
City Manager Approval
Item to be presented by:
Jeff Kolin
NEW BUSINESS
DATE: November 28, 1995
SUBJECT: DRAFT ENVIRONMENTAL IMPACT REPORT -- PROPOSED CHIQUITA.
CANYON LANDFILL EXPANSION AND 'RESOURCE RECOVERY
FACILITIES; SUBMISSION OF ADDITIONAL CITY COMMENTS TO
THE REGIONAL PLANNING COMMISSION
DEPARTMENT: City Manager/Special Projects
BACKGROUND
Staff reported on the proposed expansion to the Chiquita Canyon Landfill at the regular Council
meeting of August 22, 1995, and prepared a letter of technical comments for the Regional
Planning Commission meeting of August 23, 1995. Council received the report and comments
from the public, particularly from the community of Val Verde, and directed staff to present the
letter to the Regional Planning Commission, and then to re-examine the Draft Environmental
Impact Report and to expand the technical comments as necessary. The previous staff report,
detailing the proposed expansion, is in the Council reading file.
The Regional Planning Commission conducted a public hearing on the application on
Wednesday, August 23, at Valencia High School, and visited the site later that month. The
hearings have been continued to November 30, and written testimony will be accepted through
that date. Staff has prepared the attached letter to be presented at that meeting, as Council
directs.
At the Council meeting of November 14, 1995, residents of Val Verde presented additional
comments to the Council, requesting that Council support their request for denial of the.
application. They also had earlier met with the Mayor and requested assistance in hiring an
air quality consultant. Staff has met with the City Manager to discuss the costs of doing this,
and consider that a "not -to -exceed" expenditure of $8,000.00 to be appropriate, since the City
will also benefit from the consultant's work.
Staff has learned from testimony presented to the Regional Planning Commission that the
expansion is opposed by the Val Verde Civic Association, LASER, and SCOPE, and is supported
by the Castaic Chamber of Commerce, the Santa Clarita Valley Chamber of Commerce, and the
Valencia Industrial Center Association and the Castaic Town Council has taken no position.
A P P Ru 00 E 0 Agenda Item:1*3,
The Chiquita Canyon landfill is an existing Class III waste disposal facility located on the north
side of SR 126, west of I-5, east of Chiquita Canyon Road, and immediately south of Val Verde.
It has been operated by Laidlaw Waste Systems since 1986, on land leased from the Newhall
Land and Farming Corporation. The landfill is currently operating under a Conditional Use
Permit (C.U.P.) issued by Los Angeles County; the permit will expire in 1997. The applicant has
requested a new C.U.P. to expand the landfill capacity by 29.4 million tons beyond its present
permitted capacity of approximately three million tons. In addition to increasing the net
capacity, the applicant is requesting an increase in tonnage per day (tpd) from 5,000 to 10,000
tpd. The proposed site service life would be 10.5 years at this rate of disposal. (The Regional
Planning staff report recommends that the daily limit be maintained at 5,000 tpd.) The
applicant is also requesting permission to include a Materials Recovery Facility (MRF) and a
Household Hazardous Waste (HHW) on the site, accessed from Wolcott Way, and to conduct
composting operations for sewage sludge and green waste.
Special Projects, Engineering, and Community Development staff members have re-examined
the Draft Environmental Impact Report (DEIR), and have prepared a second comment letter
(attached) to the Regional Planning Commission. This letter reiterates the previously stated
comments, and provides additional comments on the significant unmitigated visual and air
quality impacts, and on groundwater contamination, traffic impacts, cumulative impacts, and
on alternatives to the proposed landfill process and design, including policy and technology
alternatives.
Staff believes that additional air quality analysis is required, and that it would be appropriate
to allocate not more than $8,000.00 to assist the Val Verde Civic Association in funding a
consultant to perform an independent evaluation of the DEIR's (and technical appendices') air
quality analysis and mitigation, and to devise additional mitigation measures or suggest studies
as appropriate. The DEIR now states that air quality impacts are significant, and cannot be
completely mitigated. Because the landfill is located directly upwind from Santa Clarita, air
quality deterioration will negatively affect the city. Suggestions from an independent expert,
if implemented, may help to reduce these impacts.
WORIMMKO �►
1. Receive report, and direct staff to present the attached letter and supporting oral testimony
to the Regional Planning Commission at the public hearing on November 29, 1995.
Approve the appropriation of funds in the amount of $8,000.00 to Special Projects Account
No. 01-4103-227 from the Contingency Reserve Account No. 01-4101-290 to pay for an air
quality consultant to conduct independent review of the Chiquita Canyon Landfill
Expansion DEIR, and to perform requested air quality impact studies.;
1. Letter from City Manager to Regional Planning Commission
2. Staff Report of 8122/95
.Ity of
Santa Clarita
23920 Valencia Blvd.
Phone
Suite 300
(805) 259-2489
Santa Clarita
Fax
Califomia 91355-2196
(805) 259-8125
November 28, 1995
Mr. James Hard
Director of Regional Planning
Los Angeles County
320 W. Temple St.
Los Angeles, CA 90012
RE: CONDITIONAL USE PERMIT 89-081- (5)
LAIDLAW WASTE SYSTEMS
CHIQUITA CANYON LANDFILL EXPANSION
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR)
Dear Mr. Hartl:
This Ietter is to provide you with additional technical comments from the City of
Santa.Clarita to respond to the Chiquita Canyon Landfill Expansion DEIR and
also to the replies prepared by the applicant to previous comments submitted at
the August 23, 1995, public hearing.
Since the August 23 hearing, city staff members have revisited the DEIR, and
have prepared expanded comments in several issue areas. We have attended all
of the public hearings on the project to date, and have observed the applicant's
testimony and exhibits. We have also received and reviewed the applicant's
summary document, addressed to the Regional Planning Commission, "Responses
to Issues Raised at the August 23 Public Hearing By Opponents of the Proposed
Chiquita Canyon Landfill (9/25/95)," prepared by Latham do Willdna, Attorneys
at Law, and the "Revegetation and Erosion Control Program" (Oasis Associates,
Inc.). In order to determine if any of the City's concerns could be alleviated
through changes to the proposed project, we have met with the applicant to
discuss them, and have received positive responses, which are also discussed
below.
In our previous letter of August 22, 1995, we stated our concerns regarding
impacts to traffic, site access, biota, Santa Clara River, air quality, geology and
hydrology, and the analysis of project alternatives. ' We would like to comment
further on the issues of air quality, visual impacts, alternatives to the project,
and the foundation of the "needs analysis" on which the argument for expanding
the landfill is based.
PRINTED ON RECYCLED PAPER
Mr. James Hard, Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 2
Air Quality Impacts
It is our understanding from the applicant that Laidlaw is conducting a
specialized air quality impact analysis, which is anticipated to be complete
prior to the November 30 hearing. This analysis may respond to our
previous concerns, and may provide mitigation measures in addition to
those already suggested by the South Coast Air Quality Management
District (SCAQMD).
Additionally, the Val Verde community has contracted an air quality
consultant to provide an independent review of the applicant's analysis.
The Val Verde Civic Association has requested that the City partially fund
this study.
Should feasible new mitigation measures, including technological or
operational alternatives, be recommended by either study, and/or required
by the SCAQMD, we request that they be added to the conditions of
approval and the mitigation monitoring program for the project.
Visual Quality Impacts
In our previous letter, we requested that the applicant provide a landscape
plan for public review, and that landscaping of the highway property
frontage be added to the project conditions. We received the plan for review
on Friday, November 17. It appears to be an adequate program for
developing a site-specific revegetation plan, provided that the recommended
soil testing and planting techniques are followed.
The applicant's proposed method for preventing landfill gases from
impairing plant growth (synthetic geotextile membrane over one foot of low
permeability soil underlying the 1.5 foot planting soil layer) appears to be
consistent with the sucoeasful methods of landfill gas venting cited on P. 20
of the report. The plant palette, described in Appendix G of the
Revegetation Plan, includes a reasonable selection of tree, shrub, and
perennial species, and a hydroseed mix of annual wildflowers and grasses.
Additional appropriate tree and shrub species which are native to the local
chaparral community would include Scrub Oak (Quercus berberidifolia),
California walnut (Juglans californica), California sycamore (Platanus
racemosa), Sugar bush (Rhus ooata), Rabbitbrush (Chrysothamnus
nauseosus), Bladderpod Usomeris arborea), Our Lord's Candle (Yucca
whipplei), Hoary -leafed ceanothus (C. crassifolius). Invasive exotics, such
as Cistus, Plantago, Spartium, and Tamarix should be avoided. r
sharelchg11128.cmk
Mr. James Hard. Director of Regional Planning
Chiquits Canyon Landfill Expansion
November 28, 1995
Page 3
The report cites the Coastal Landfill Revegetation Project as an example of
a successful revegetation installation (Appendix L). However, some
concerns are evident in the photographs included: some plant species
chosen for this project are non-native or non -indigenous to the immediate
area of the landfill. For example, on Figure L-4, the tree species evident in
the Bottom Photo appear to be Monterey pines, and on Fig. 1-8, both
EucalXptus and mania are shown. The latter two species are both non-
native and potentially invasive; the former may not be the best choice of a
native tree species for the site. No substitutions of exotic (albeit easily
commercially available species) should be allowed from those in the
Revegetation Plan. The Conditions of Approval for the project should
restrict any substitutions to the discretion of the Department of Regional
Planning, and require review by the staff biologist.
Finally, the Conditions should specify a "coverage/screening" or
"establishment" goal for landscaping of the property frontage. For example,
plant materials should be selected and located to achieve 80% visual
{ — screening after a period of three years following planting; landscaping of the
property frontage should also be conditioned to be installed in conjunction
with the entry road improvements. .
Traffic Impacts
The DEM did not assess the impacts of the project on the operation of the
SR 126/Interstate 6 interchange to determine the applicant's proportionate
share of the planned improvements to the interchange. The applicant's
share of the improvements should be determined, and should be assigned
to CALTRANS at a defined time in the permit process, such as prior to
issuance of grading permits for the expansion area.
We also request that the County consider requiring that traffic signals be
installed at the exit ramp locations at I-MR126 for the interim period
between project approval and initiation of CALTRANS improvements to SR
126 and the interchange (should the project be approved.)
Improvements to the immediate Property frontage, such as lengthening the
left -turn pocket for additional stacking distance, adding acceleration and
deceleration lanes, and adding a second scale at the landfill entry would
also serve to mitigate apparent impacts. These should be considered for
addition to the mitigation monitoring program and the Conditions of
Approval.
sharelchgll 128.cmk
Mr. James Hard, Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 4
Geotechnical Hazards
The DEER does not fully disclose information regarding landfill liner
failures associated with the Northridge Earthquake. One of the most
important representations a modern landfill can make is that its liner has
been tested and checked for flaws, has been installed with all seams
carefully sealed, and has been constructed in a manner to prevent
inadvertent damage during initial placement of waste. Damage to the
landfills occurred at both the Chiquita Canyon and the Lopez Canyon sites
during the magnitude 6.8 earthquake.
At Chiquita Canyon, the synthetic geomembrane liner sustained a tear over
13 feet in length and nearly 10 inches in width. Why is there no cause -and -
effect description of something that is so important? Nothing is said in the
DEIR about the circumstances of these incidents (e.g., on a slope, above an
area of settlement, previously mapped faults or landslides in the area, liner
composition, underlying ground deformation, poor installation, ripped a few
inches or a few feet), despite the fact that such incidents should serve as a
valuable lesson for the next time someone installs one of these liners.
Also, is there any possibility that this could have occurred at locations
beneath the landfill footprint which are covered and could not be observed?
The DEER does not indicate any attempt to make subsurface observations,
directly or indirectly. Stating that the tear was easily and rapidly repaired
is interesting but should not be all that is mentioned. The DEER (or
addendum) must address this issue more fully before this landfill is
expanded and designed, permitted, and constructed in this seismic
environment
According to the State Division of Mines and Geology, there was fault
rupture at the surface during the Northridge earthquake, although it was
limited and not readily detected in the several days and weeks following the
event. It was apparent that ground deformation of other types occurred
(e.g., compressional, extensional, and left -lateral deformation) which
disrupted pipelines, curbs, streets, sidewalks and natural ground. The
DEIR gives no indication of the magnitude of. these observed ground
deformations to compare with the magnitude of surface fault rupture that
have been observed in past earthquakes. Some discussion of the potential
impact of these ground ruptures and deformations should be presented,
particularly with respect to observations at Chiquita Canyon.
sharc%cbg11128.cmk
Mr. James Hartl, Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 5
In the Potrero Canyon ground deformation, extensional fractures occurred
over about a 3 -kilometer (1.8 mile) length (National Center for Earthquake
Engineering Research, 1994) in a zone 5 to 30 -feet wide, with open cracks
up to four inches, and vertical movements of two feet (Earthquake
Engineering Research Center, 1994). Individual south dipping bedding
plane shear surfaces (small faults) showed thrust -type displacements of up
to six inches. Substantial field work was done following these preliminary
observations so that additional details should be available on the magnitude
of these features and their origin. It is not clear what impact this sort of
deformation might have had if it had occurred beneath the Sunshine
Canyon or Chiquita Canyon landfills. The DEIR should provide detailed
analyses or modeling studies to address this issue.
In the Granada Hills area, there is a 5 kilometer (3 -mile) long zone of
extensional cracks, compression, and left -lateral deformation which
contributed to the failure of numerous pipelines. This has been attributed
to lateral spreading and secondary faulting on the Mission Hills fault zone
(National Center for Earthquake Engineering Research, 1994). It is not
clear what impact this sort of deformation might have had if it had occurred
beneath the Lopez Canyon or Chiquita Canyon landfills. Additional
detailed analyses or modeling studies to address this issue should be
provided.
It is also not clear whether these deformations are of the type and
magnitude that would be as serious as a one or two -foot offset from an
active fault which is regulated by both the Federal and State siting
guidelines as a "fatal flaw' for the site. Such a determination should be
made, however, as a part of the project analysis (whether in the DEIR or
and addendum) based on the probability that such deformation could occur
at the Chiquita Canyon site.
Alternatives to the Project/Alternative Sites
The Draft Environmental Impact Report (DEIR) for the proposed Chiquita
Canyon Landfill Expansion and Resource Recovery Facility does not
sufficiently address the ability of alternatives to meet the ongoing needs for
solid waste disposal generated by Los Angeles County. Additionally, the
DEIR incorrectly creates the impression that Chiquita Canyon Landfill
would provide an additional in -county waste management option that would
offer both permitted daily disposal capacity to avoid short term shortfalls
and contingency situations produced by potential closures of other disposal
1 sites and general capacity to meet 15 -year requirements as mandated by
share%chg11128.cmk
Mr. James Hard, Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 6
California law (19). The DEIR also fails to adequately analyze the ability
of landfills in adjacent counties to meet the disposal requirements of Los
Angeles County. AB 939 in California state law does not mandate that
counties maintain 16 years of disposal capacity within their county. A
detailed analysis of alternatives available to help meet Los Angeles
County's ongoing solid waste needs is included in Attachment 1 and should
be considered a portion of the City's comments regarding the DEIR for
Chiquita Canyon.
Section VII, Page VII -2
The DEIR project objectives are not comprehensive with regard to the
California Integrated Waste Management Act of 1989 (AB 939) and its
subsequent amendments. In addition to planning for 15 years of permitted
disposal capacity, the County is also required to prepare a non disposal
facility element (NDFE). The NDFE must include a description of new
facilities and any expansion of existing facilities which will be needed to
accomplish the diversion goals of AB 939. More emphasis should be placed
on the proposed Materials Recovery Facility (MRF) and Household
Hazardous Waste Drop Off Facility (HHWF) since it would better serve the
diversion needs of the County rather than an expansion of the existing
landfill.
Section VII, Page VII -16
The DEIR concludes that the No Project alternative would prevent the City
of Santa Ciarita and other communities from meeting their diversion goals.
This conclusion is not justified since the construction and full operation of
the MRF, HHWF and composting facility is not scheduled to be built until
it is economically feasible for Laidlaw Waste Systems. The DEIR does not
include a time line for the construction of these recovery facilities, nor does
it include any statements which guarantee that the facilities will be built.
In fact, the statement that they will be built when economically feasible
leads many to conclude that if continued landfill expansions and new sites
are permitted by Los Angeles County, such needed recycling facilities will
never be built.
Numerous public comments have been received regarding the co -composting
operation recommended and described in the DEHL Operations such as
those detailed in the DEER do have the potential for creating odors. The
applicant should propose odor control measure including possible enclosed
wind rows in a structure which would allow capture of the odors and then l•
a filtering process to be used for odor control. The applicant has also
share\chg11128.cmk
Mr. James Hard. Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 7
included in the project description, the possibility of in vessel composting
which would provide an environmentally superior process which could
reduce odor problems, allow for a much broader selection of materials to be
included in the composting process and speed the production of compost
materials. The issue of odor control also deserves further attention with
the possibility of formation of a community advisory council which would
evaluate and make recommendations for further improvements on odor
control measures on at least an annual basis.
The DEIR is deficient since it does not identify or address all feasible
alternatives to the Chiquita Canyon Landfill Expansion. The DEER does
not address the removal of inert material from the solid waste stream,
thereby reducing the need for landfill capacity. A significant part of the
waste stream is inert construction and demolition (C&D) wastes which is
currently disposed of as Class III waste in landfills and inert facilities.
Adequate local capacity designated for inert materials is readily available,
the DEIR should address the impact of restricting the disposal of inert
{-' materials to only those landfills designated for inert materials.
Section VII, All Pages
Section VII, pages VII -17 thru 33
The DEIR is inaccurate in its assessment of the various daily capacity and
expansion alternatives. The City of Los Angeles, the Bureau of Sanitation,
Solid Resources Action Plan indicates that the City will seek to extend the
Conditional Use Permit for the Lopez Canyon Landfill beyond the year
2001. The DEIR does not address the expansion of Lopez Canyon, which
could potentially add 4,000 tons per day of capacity to the region. In
addition, the DEER does not address capacity currently provided and
available by the various Orange County landfills which are currently
soliciting long term contracts.
The DEIR is inadequate since it bases its alternative analysis on the Solid
Waste Management Action Plan for IDS Angeles County which was adopted
by the County Board of Supervisors in 1988. This Action Plan embraces a
landfilling policy and places a low priority on AB 939 diversion programs.
The Action Plan needs to be updated to emphasize and implement source
reduction, diversion, and transformation programs.
�} Additionally, as mandated by AB 939, the County has not completed the
✓} County Integrated Waste Management Plan (CIWMP) which integrates the
Source Reduction and Recycling Elements (SRRE) from all cities and
sharekhg11128.cmk
Mr. James Hart(. Director of Regional Planning
Chiquita Canyon Landfill Expansion i
November 28, 1995
Page 8
unincorporated areas in the County nor have they completed the County-
wide Siting Element (SE). It is for these reasons that the DEIR should be
rewritten to include the most recent data which incorporates the
information that will be presented in the CIWMP and SE.
Section VII, All Pages
The DEER is inadequate in its evaluation of waste being transported out of
state. For example, the impact of the IA Paz County Landfill should be
considered in the County s overall waste shed since waste from this region
is currently going by truck to La Paz.
Section VII, Page VII -34
The DEIR does not analyze the use of El Sobrante Landfill as an out -of -
county alternative. The El Sobrante Landfill will take municipal solid
waste from communities within Los Angeles County. The El Sobrante
Landfill can potentially provide a significant portion of Los Angeles
County's required daily disposal capacity.
Section VII, Page VII -37
Further, the DEIR does not analyze the ability of regional approaches to
manage excess capacity in adjacent counties and develop regional disposal
plans as currently under study by the Southern California Association of
Governments (SCAG).
The DEER does not adequately address the rail haul alternative. Waste
from the Los Angeles area has been sent to Utah by rail.. In. addition, the
Mesquite Regional Landfill recently received approval from the host county.
The DEIR should include a comprehensive discussion of the rail haul
alternative. These alternatives* should not merely be summarily dismissed
as more expensive or more environmentally damaging without supporting
data and study.
Section VII, Page V1141
The DEIR is inadequate in its approach to alternative landfills. Many of
the alternative landfills were eliminated since they did not meet the project
objectives. One of the project objectives is to provide Los Angeles County
with disposal capacity for both short and long terms*. Therefore, the DEIR
should include a discussion of the cumulative disposal capacity of all j
sharelchg1112g.cmk
Mr. James Hard. Director of Regional Planning
(� Chiquita Canyon Landfill Expansion
November 28, 1995
Page 9
alternative landfills instead of capacity base don individual landfill
alternative scenarios.
Section VII, Page VII46
The DEER is inadequate in its evaluation of volume capacity at the various
landfills. The use of yard materials as alternative daily cover (ADC) and
the use of thin synthetic daily cover increases the volume available for
landfills; the normal soil daily cover can take up to 30 percent of the
physical volume of a landfill. The DEER does not consider ADC in its
analysis which could provide an increased disposal capacity. In addition,
landfill technologies such as leachate recirculation to ` accelerate
decomposition, biostabilization and landfill reclamation are not considered
in the DEIR. Section VII, Pages VH 41 thru VII -45. Additional comment
on this area is included in the attachment on Alternatives.
The DEER should analyze the additional disposal capacity provided by the
various expansion of existing landfills, long distance truck transport, rail
�) haul projects and diversion programs to include a diversion beyond 50
percent since some cities in Los Angeles County have set diversion rates
higher than the mandated goal. The City of Los Angeles has set a 70
percent goal according to the City's Solid Waste Management Policy Plan.
Section VII, Pages VII47 thru VII49.
The City of Santa Clarita has commissioned a study to evaluate Los Angeles
County's Disposal and Waste Diversion options. The Study will provide a
detailed analysis on the County's solid waste generation based on changing
socio-economic climate including the impacts of the current changes of
economic base, demographics, income structure, and waste disposal
generation and demand. Information from this report will provide sufficient
data to perform a more comprehensive evaluation on the alternatives to the
expansion at Chiquita Canyon Landfill. Many of the initial points covered
in the City's comment letter and attachments are preliminary findings of
the study. A final draft will be prepared for technical comment by the City
by November 30,1995. The final draft will be available in December 1995.
Section VII, All Pages
The DEER is inadequate in its conclusion that waste reduction and
alternative technologies cannot offset the ultimate"need for additional
landfill capacity as projected by Los Angeles County. Page 149. No
justification or explanation is given for this conclusion.
share\chg11128.cmk
Mr, James Haul, Director of Regional Planning
Chiquita Canyon Landfill Expansion
November 28, 1995
Page 10
The assumption is made that no more than 50 percent can be achieved
through these diversion methodologies. Additionally, no credit is given for
mechanical volume reduction techniques, transformation, or source
reduction efforts.
Thank you for this additional opportunity to comment on this project. If you
would.like to discuss the City's concerns, please call me at (805) 2594900.
Sincerely,
George A. Caravalho
City Manager
GAC:jk:cmk:gmm
Attachment
( t
cc: Carl Newton, City Attorney "
Merry Farmer, Val Verde Civic Association
SCOPE
Rodney Walter, Chiquita Canyon Laidlaw Waste Systems, Inc.
David Vannatta, Planning Deputy, 5th District
share\cbgll l28.cmk
AGENDA REPORT
Ci Manage Approval
NEW BUSINESS
DATE: August 22, 1995
SUBJECT: Chiquita Canyon Landfill
Technical Comments to
Commission on August 23,
DEPARTMENT: Special Projects
Item to be presented by:
Hazel Joanes
Expansion: City Response and Proposed
be Presented to the Regional Planning
1995.
The Chiquita Canyon landfill is an existing Class III waste disposal facility located on the
north side of SR 126, west of I-5, east of Chiquita Canyon Road, and immediately south of Val
Verde. It has been operated by Laidlaw Waste Systems since 1986, on land leased from the
Newhall Land and Farming Corporation. The landfill is currently operating under a
Conditional Use Permit (C.U.P.) issued by Los Angeles County; the permit will expire in 1997.
The applicant has requested a new C.U.P. to expand the landfill capacity by 29.4 million tons
beyond its present permitted capacity of approximately three million tons. In addition to
increasing the net capacity, the applicant is requesting an increase in tonnage per day (tpd)
from 5,000 to 10,000 tpd. The proposed site service life would be 10.5 years at this rate of
disposal.
The applicant is also requesting permission to include a Materials Recovery Facility (MRF) and
a Household Hazardous Waste (HHW) on the site, accessed from Wolcott Way, and to conduct
composting operations for sewage sludge and green waste.
Staff has reviewed the Draft Environmental Impact Report (DEIR) for the project, and has
prepared a letter (attached) expressing numerous concerns about the quality of analysis. In
addition to general policy questions regarding the expansion or creation of new landfills, the
issues of concern to the City are primarily related to land use, traffictaccess, biota/Santa Clara
River, air quality, and the analysis of project alternatives, including policy and technology
alternatives to the proposed landfill process and design. Additionally, staff included comments
regardipg geotechnical hazards, flood hazard, nonpoint pollutants, and cultural resources.
S I SHAREi CHQAC82ZCMx
8/10/95
Staff has been approached by the Val Verde Civic Association, and has provided some
assistance to them with respect to presenting their concerns to the Regional Planning
Commission, and supported them in requesting an extension of the public review period, The
concerns expressed -parallel those cited by staff,: particularly those regarding air quality,
groundwater quality, noise, odors, vector control, visual impacts, and seismic safety. Staff has
also heard a presentation by the proponent, Laidlaw Waste Systems, Inc.
From previous Council direction, staff is continuing to review the DEIR in greater detail, and
intends to submit additional technical comments on the document to the County prior to the
deadline on November 15, 1995. The Regional Planning Commission began the public hearing
on Wednesday, August 9th, and continued it to August 15th, for the applicant's presentation.
A subsequent date for opposition comment has been scheduled for August 23, at 6:00 p.m., at
Valencia High School.
Staff believes that a reasonable approach at this time is to continue to follow the public hearing
process, and to provide the Regional Planning Department staff and the Regional Planning
Commission with additional technical comments on the DEIR. Assisting the Val Verde Civic
Association in their efforts to oppose the landfill would also be consistent with City policy on
Elsmere Canyon, i.e., to pursue the development of alternatives that do not rely on urban
landfills.
RECOMMENDATION:
Receive report, and direct staff to (1) address City concerns in greater depth, using
documentation from the Elsmere hearing process as a resource, and to pursue resolution of
these concerns with County staff; (2) assist the Val Verde Civic Association in their opposition
to any expansion of the existing landfill; and (3) to present the attached letter and supporting
oral testimony to the Regional Planning Commission at the public hearing on August 23, 1995.
SISHARSICHQAG*=CUK
8/10/95
I. INTRODUCTION
The Draft Environmental Impact Report (DEIR) represents the culmination of a Los Angeles
County policy to manage the solid waste at the lowest possible cost. The County solid waste policy
has evolved over the past three decades, from open burning in the 1960s, incineration in the late
1970s and early 1980s, to the current landfilling policy adopted in 1988 in the Solid Waste
Management Action Plan for the Los Angeles County. This County policy has several facets:
1. A regional public landfill system;
2.- Fifty years of permitted capacity in public ownership;
3., Encourage recycling and composting;
4. Direct billing of full cost for MSW management;
5., Expand existing landfills; and
6. Develop new landfill capacity..
The County Policy needs to be updated and the non -landfill facets emphasized and
implemented. To date, the County has not completed the Integrated Waste Management Plan which
integrates the SRREs from all the cities and the unincorporated areas of the County or the Siting
Element, both of which are required by AB 939. Further, the facets of the Action Plan that support
diversion have been given low priority compared to landfilling. The County appears to be avoiding
the policy shift required to implement AB 939.. The County's position seems to be one of grudging
acceptance of diversion, disbelief that diversion goals can be met and a rush to develop the landfills
that are suggested by the "time -to -crisis" approach.
The County has yet to adopt County -wide policies that would embody the integrated waste
management hierarchy: 1) reduce, 2) recycle, and 3) energy recovery and landfill. Such policies
would place goals and programs implementing diversion (reduction and recycling) before expanding
existing landfills.
chiquitampd
Review of the DEIR for the proposed expansion to Chiquita Canyon Landfill reveals several
serious deficiencies that undermine the proposed scale of the project, and even call into question the
need for the expansion at all. These issues are interrelated, focussed around the anticipated amount
of Municipal Solid Waste (MSW) that will require disposal over the next 50 years in Los Angeles
County. A Solid Waste Disposal Capacity Analysis for Los Angeles County, prepared by The
Gibson Company for the City of Santa Clarita, January 1994, shows that County disposal
requirements would be a negligible fraction of the capacity projected for the proposed landfills in Los
Angeles County. In the Gibson Company's scenario based on historical per capita waste generation
rates, increased diversion to 50 percent, plus reasonable expansion of existing landfills, only 3,635
tons per year (11.6 tons per day, 6 -day week) would require additional disposal capacity in the year
1020. This scenario does not include the option of rail -haul to existing or proposed large landfills
out -of -County. With rail haul, excess capacity for disposal of waste generated in Los Angeles County
is projected. Therefore, the 10,000 tons per day proposed capacity at Chiquita Canyon Landfill
would be utilized to provide disposal space for waste generated outside Los Angeles County and
transfer hauled to Chiquita.
One effect of the May 1994 United States Supreme Court decision in C. & A. Carbone vs.
Town of Clarkstown was to remove local government "flow control' restrictions on waste
movements across state boundaries. Interjurisdictional movements of waste within a state
theoretically could be controlled by State law, which California has not chosen to do. In the absence
of inter- and intra -state "flow control' authority, local governments have no control over where
privately -collected waste is disposed -- either to keep it within a jurisdiction or to keep out -of -
jurisdiction waste from entering. A privately -owned landfill, such as Chiquita Canyon Landfill has
no restriction on where the waste it accepts originates.
Because Los Angeles County does not need the vast new landfill capacity for its own disposal
needs, the facility would end up serving the disposal needs of non -Los Angeles County waste. The
Chiquita Canyon location, convenient to Interstate 5 via SR 126, opens up its capacity to the entire
Ventura County area of California, particularly the communities of Fillmore, Santa Paula, Oxnard and
2 chiquitampd
Ventura. Is it wise public policy for Los Angeles County to provide avast daily disposal capacity for
many years for other jurisdictions?
The issues discussed in detail in the following sections include:
II, Projection of Solid Waste Generation in Los Angeles County;
III. Inclusion of Inappropriate Materials in Class III Landfill Disposal Calculation; and
IV.. Limited Consideration of Alternatives to the Proposed Project
chiquitampd
II. PROJECTION OF SOLID WASTE GENERATION IN LOS ANGELES COUNTY
A. CHANGING SOCIO-ECONOMIC CLIMATE
The DEIR does not take into account the impact of changes in population
demographics and economic activity on waste generation. Since the publication of the County Action
Plan in 1988, Los Angeles.County has seen its robust economy take a downturn and stagger with the
loss of industries, jobs and wage growth. In the County, for example::
• there were 135,000 fewer non-agricultural jobs in 1994 than in 1988;
• unemployment in 1988 was hovering around 5 percent, but has since doubled to about
10 percent in 1994; and
• jobs in the aerospace/high technology industries have declined by 45 percent, which
translates to the loss of 125,200 jobs since 1988.
While the national recession was declared over in 1991 by the Council of economic Advisors
as other regions of the United States rebounded, in 1995 Los Angeles County remains mired in the
recession with hopeful signs of weak upward swing to the end of the decade.
1. Economic Restructuring
Although not unique in undergoing restructuring from a manufacturing to a
service and information -based economy, Los Angeles is experiencing a far more rapid, intense, and
complex transformation of its urban economy (Soda, Morals and Wolf, 1983). In addition to the loss
of aerospace jobs, employment losses hit a broad range of the County's economy.
4 chiquita.wpd
For example:
• The retail sector lost nearly 62,000 jobs, construction lost 35,000 jobs, public
employment lost nearly 15,000 jobs, and the services sector remained about 10,00
jobs below its prior level (Wolf and Grigsby, 1995),
• The value of two-way trade in the Los Angeles Customs District, which grew by 13
percent during the 1988-89 period; rose by only 7 percent in the 1994-95 time period.
• The County received 50,200 housing unit permits in 1988, but only received 25,300
in 1994, a decline of 50 percent.
More recently, Los Angeles County, the largest employer in the County, is contemplating the
possibility of reducing its workforce by 18,000 workers in social services and health care. The
Federal government, the County's second largest employer, will reduce its workforce dramatically
over the next seven years. The Los Angeles Unified School District is the third largest employer and
has been trimming its employees for several years. Among the largest private sector employers,
several such as Hughes Aircraft, Northrop, Rockwell International, McDonnell Douglas, and TRW,
Inc, Are particularly vulnerable. For several years, layoffs have been implemented at, Pacific Telesis
Group, GTE, Times Mirror Co., Los Angeles Department of Water and Power, County-USDC
Medical Center, Pacific Enterprises, and neighboring Orange County. There are some bright spots
in the film and entertainment industries as well as professional business services, but these growth
sectors cannot compensate for the larger and broader decline.
Finally, there are signs that Los Angeles' glass manufacturing will soon disappear just as did
automobile manufacturing in the last decade. Other low profit margin industries have begun to feel
the initial impacts of the free trade accord with Mexico.
5 chiquita,wpd
2. Changing Demographic Climate
Los Angeles County continues to grow, from 7,477,400 people in 1980 to
8,863,200 in 1990 to an estimated population of 9,194,400 in 1993. The annual rates of growth have
declined from about 1.6 percent a year from 19880 to 1990, to 1.2 percent since 1990. More
importantly, Los Angeles County has undergone a dramatic shift in its ethnic composition since 1988.
White -Non -Hispanic share will decline from 41 percent in 1990 to 33 percent in the year 2000.
Moreover, the Hispanic share of the population (at 38 percent in 1990) is projected to rise to 46
percent by the year 2000. Hispanic population growth is fueled by larger family sizes and the
continued influx of immigrants. White Non -Hispanics are declining in share due to the outflows of
population. For example:
• During the 1992-93 period, 112,800 persons moved out of Los Angeles County.
• Southern California Association of Governments has just recalibrated its projections
for the five -county area downward by over half a million. They estimate that about
95,300 persons will leave the five -county SCAG region each year from 1995 to 1999.
After the year 2000, the number of annual out -migrants from the SCAG region will
rise to 135,000.
• The State Department of Finance estimates that almost all the growth Los Angeles
County will experience over the next five years will result from immigration from
abroad.
Los Angeles County has been transformed from a primarily white (Non -Hispanic) population
to one where Hispanic-, Asian-, and African-Americans account for 60 percent of the County's
population.
6 chiquitampd
3, Changing Income Structure
The vacuum created by the loss of large number of high wage jobs associated
with manufacturing and aerospace has been filled by service sector jobs paying lower wages with
fewer benefits. About two-thirds of the County's Hispanic population are in non -manufacturing jobs.
Hispanic-, Asian- and African-Americans are more likely to be located in the services sector, which
is devoted to the generic consumption and maintenance activities required or expected in large urban
areas. The kinds of retail and services provided -- markets, small to medium size retail stores,
restaurants, car repair and medical care -- account for most of the low-wage job growth experienced
by Los Angeles County since the late 1980s.
Workers in lower occupation levels receive lower wages. With less discretionary income to
spend, consumer patterns are less wasteful. Many anecdotal observations have been made about the
"conservation behaviors" of recent immigrants and lower income households who continually seek
ways to extend the uses of material goods and products.
4. Implications for Waste Disposal Demand
The population forecast used in the DEIR is too high. Any population
projection estimated prior to 1990 will inflate future population growth. In 1993, the State
Department of Finance lowered its population projections. The Department of Finance will release
its new projections in November 1995 and the general expectation is that the numbers will be still
lower. In 1995, SCAG adjusted its 1990 population projects downward for the five -county region.
The center for the Study of California's Economy has also lowered its population projections in its
latest 1995 report.
The shift from a manufacturing to a service base economy will change waste disposal demand
for Los Angeles County. In general, service base economies are more likely to use recyclable
materials, create less sludge, and produce refuse that can be converted to fuels. Many of these newer
7 chiquitampd
industries are more efficient and produce less waste.
The aggregate numbers hide significant compositional changes. The latest projections are
lower but all assume some degree of growth. More importantly, the growth will be driven by
immigration primarily from Mexico, Latin America and Asia. These change sin the components of
growth and subsequent compositional changes challenge basic assumptions that waste disposal
patterns of the past will be replicated in the near future.
Lower household incomes mean less waste per capita is generated. The association of higher
incomes with greater consumption and waste has been well established. The current outlook of
greater shares of lower income, non-white populations in Los Angeles County over the next decade
projects to declining tonnage of waste disposal demand.
B. WASTE COMPOSITION
The DEIR does not indicate the relative percentages of the waste stream and waste
categories that relate to each of the three sectors impacted by AB 939 (residential, commercial,
industrial), nor indicate how this breakdown would affect recycling alternatives and projected waste
stream growth. The data submitted by Los Angeles County local jurisdictions in their Source
Reduction and Recycling Elements (SRREs) contradicts the testimony by Jack R. Michael
(supporting the DEIR) stating that the commercial, industrial, construction and demolition waste
stream is nearly 67 percent of the disposed waste stream. In fact, the County profile indicated by the
aggregated SRREs shows the residential sector to be 46 percent of the County waste stream, with
the combined industrial/commercial waste stream representing 56 percent. Construction waste is
shown within the industrial/commercial waste stream in the SRREs unless it is sent to inert landfills
(non -class III permitted), in which case it is usually not counted: Furthermore, the County historically
has not included inert landfill capacity or tonnage in their capacity/tonnage growth projections and
thus excluded most inert construction waste debris.. This has considerable implications for recycling
alternatives. The most rapid increase in recycling rates has come in the residential sector, which was
8 chiquita.wpd
substantially behind the commercial/industrial sector in base year diversion rates and/therefore,
significantly affected by curbside recycling and yard trimmings programs that have started -up since
1990.
C. IN -COUNTY DISPOSAL CAPACITY: BASE YEAR
On what basis did the DEIR select disposal facilities for use in calculating 1994 base
year in -County disposal capacity? How is it similar/different from the in -County disposal sites utilized
by the County in past years, in their 1995 disposal survey, and in the CIWMB listing of landfills from
LA County which pay disposal fees to the Board of Equalization? The DEIR relies heavily on County
data for its projections, yet the County has not been consistent in its definition of disposal capacity
over time, nor consistent with the fee -paid tonnage calculations made by the CIWMB based on Board
of Equalization records.
The eight following Class III landfills reported tonnage and paid fees in 1994 to the State
Board of Equalization from Los Angeles county that are not included in Table 2-2, paged 1-19 of the
DEIR.
• Brand Park Landfill;
Antelope Valley Public Dump;
• Azusa Land Reclamation Co., Inc.,
• Burbank Landfill Site No. 3;
• Waste Management of Lancaster;
• Pebbly Beach (Avalon) Disposal Site;
• U.S. Navy Landfill; and
City of Whittier -Savage Canyon Landfill.
Furthermore, in 1995, the County utilized Peck Road Landfill and. Reliance Pit #2 Landfill in
their solid waste quarterly disposal quantity reporting, both of which are inert landfills (and included
9 chiquna.wpd
both of these landfills also in their 1994 summary). Finally, the County has in the past included the
two waste -to -energy (WTE) facilities in their reports of disposal capacity: Under State law, these
two WTE facilities must be included in disposal calculations for 1995 goals. The missing landfills are
smaller than the ones utilized in the DEiR, but in the aggregate they can impact significantly on 15 -
year goals. The WTE facilities have been utilized well below design capacity since 1990..
D. EXPORT/IMPORT TONNAGES AND TRENDS
The DEIR does not adequately address the transfer of tonnage into and out of the
County, nor does it explain how these trends will affect use of and availability of County disposal
capacity for in -County use.
Since 1993, there has been a sharp increase in importation of waste to Los Angeles County,
based both on decreasing capacity in other counties as well as financial considerations.
In the first quarter of 1995, out -of -County waste accounted for 5.3 percent (2,583 tons per
day or over 800,000 tons per year) of all tonnage received at Los Angeles County landfills and WTE
facilities, Tonnage was drawn from as far away' as San Diego County, attracted by low disposal
charges in Los Angeles County. This trend is likely to continue upward, in part as the result of
anticipated landfill closure in Venture County. How does provision of up to 10,000 tpd on the far
north western limit of the County adjacent to Ventura County impact this importation?
E. MSW GENERATION CALCULATIONS
The underlying assumptions behind utilizing these estimates are inadequately
presented. In fact„ use of these estimates ratesare in conflict with actual year-to-year historical
growth trends (which show a gradual decline in County growth rates over the period 1982-1992) and
Draft Solid Waste Disposal Quantity Reporting Summary by County and Jurisdiction,
First Quarter 1995, Los Angeles County Department or Public Works
10 chiquitampd
current and projected demographic trends (as described in Section IIA of this document) which will
impact on tonnage growth through the year 2043, Actual County -wide disposal tonnages as reported
by County landfills to the County in 1987 and 1988 and to the State Board of Equalization for the
period 1989 through 1995 have shown downward or stabilizing trends, despite earthquake cleanup
efforts in 1994 and 1995, and contradict the DEIR growth assumptions. Also, by not including the
years 1987 through 1992 on Table 2-1, the DEIR avoids having inconsistent growth rate projections
become more noticeable to the reader,
A recent report on statewide landfill capacity noted a similar trend statewide in California.
Utilizing Board of Equalization landfill reports of"fee paid" tonnages, the report noted that daily per
capita disposal went from 7.4 pounds per person in 1985 to 7.9 pounds per person in January 1990
and 5.9 pounds per person in 1993, There are many factors impacting this drop, including the
recessionary forces cited by the County and the DEIR, demographic trends, increased utilization of
lower priced inert landfills, increased diversion activities, and changes in packaging.
The quantity of municipal solid waste (MSW) projected to be generated in Los Angeles
County in the DEIR is much too high and results in excessively high projections for County disposal
need even though the DEIR assumes 50 percent diversion,
F. LANDFILL CAPACITY NEEDS
The Los Angeles County policy that there must be excess landfill capacity equal to or
greater than the largest disposal facility (Puente Hills, at 13,200 tons per day). This policy forces the
development of larger and larger landfills. This provision of "excess capacity for emergencies is
unnecessary. In the event of sudden increases in demand for disposal space, such as natural disasters
(earthquake, fires, floods, mudslides), landfills have demonstrated the flexibility to accept sudden
surges of materials as needed. Additionally, the Integrated Waste Management Board has
demonstrated a willingness to temporarily expand permit capacity to accommodate these surges.
Further emphasis on recovery of disaster debris is also needed to divert as much material as possible
I I chiquitampd
from landfill disposal.
Because the proposed Chiquita Canyon Landfill would be privately owned, the County would
have no control over the origin of the waste accepted at the landfill. The presence of the Chiquita
Landfill within the County of Los Angeles does not guarantee that any or all of that capacity is
available for disposal of County -generated waste. Nor is it likely that capacity would be available on
short notice in the event of catastrophe or the abrupt, unexpected closure of an existing County
landfill. The owners of Chiquita, Laidlaw Corporation, can be expected to continue their current
practice at the Chiquita Canyon Landfill of entering into long-term disposal contracts with individual
jurisdictions and private haulers to keep the landfill operating at capacity. The "excess" capacity the
County includes in its planning will not necessarily be provided by Chiquita Canyon Landfill.
The County has expressed doubt as to whether the State's 50 percent diversion goal is
realistic, as discussed in Subsection ILA above, and consequently is not taking it seriously. The
County policy that 50 years of landfill capacity must be provided' is comforting to landfill managers
and eliminates serious consideration of alternatives to landfill disposal. However, in the 50 year
planning period, the entire technological approach to waste management is liable to change as much
as it has over the last 50 years. For example, in 1945, World War II recycling programs stopped,
waste piled up in unlined dumps where open burning was practiced, and waste was dumped in the
ocean. Today, this picture has changed completely, and all the alternatives discussed in Section VI
below are commercial available right now. Also, a variety of emerging technologies could become
commercial viable in the next 50 years, including; pyrolysis, plasma disintegration, methanization,
anaerobic digestion, ethanol production, and manufacture of building materials from processed
wastes. These technologies have been proven in pilot facilities, on specific components of the waste
stream (such as tires), or in other countries (such as the Japanese building block technology). These
"high tech" approaches presently are expensive compared to landfill disposal; however, as landfill
2 The policy set by the Los. Angeles County Board of Supervisors, April 5, 1998 in the Solid
Waste Management Action Plan ("Action Plan") calls for 50 years of permitted landfill
capacity in public ownership. It should be noted that the planning period required by the
California Integrated Waste Management Board is only 15 years.
12 chiquita.wpd
costs rise due to increased environmental controls and as technologies mature, cost will be less of an
impediment to commercialization.
The future of solid waste management lies in increased source reduction (producing less waste
requiring disposal or recycling), and new technologies to handle the waste that cannot be avoided or
recovered for recycling and conversion through conventional technologies -- not in providing over-
expanding disposal capacity.
13 chiquita.wpd
III. INCLUSION OF INAPPROPRIATE MATERIALS IN CLASS III LANDFILLS
The quantity of MSW projected by the DEIR as required disposal in Class III landfills is too
high. This is due not only to excessive projections as discussed in Section II, but also to the inclusion
of materials in these figures of quantities of materials that are inappropriate for disposal in the
County's Class III landfills, including: 1) inert materials, 2) wood, 3) yard waste, 4) white goods, 5)
tires, 6) crop residues, 7) manures, 8) biosolids, and 9) generated waste out -of -County. The Board
of Equalization indicates that 12,068,712 tons of waste were disposed of in Los Angeles County
landfills in 1994. If these inappropriate materials were excluded from the County's Class III landfills,
the disposal requirements in 1994 would have been 31.2 percent' less (i.e., reduced by 3,767,527
tons) in 19944, excluding importation. Importation adds an estimated 620,000 tons to the estimate,
resulting in over 14,000 tons per day of inappropriately used landfill capacity. The DEIR did not
include policy alternatives that would exclude or provide disincentives for landfilling these materials
in the County. Details on recycling/reuse of these materials is provided in Appendix A.
A. INERT MATERIALS
In 1994, the CIWMB-based calculation indicates a total of 893,085 tons of inert
materials were disposed of in landfills from MSW generated in the County. This tonnage included
earthquake debris, construction waste, demolition debris, dirt, etc. These materials are reusable or
recyclable.
In January 1994, following the Northridge earthquake, a cooperative effort between the Los
Angeles County Sanitation Districts and the City of Los Angeles Integrated Solid Waste Management
Department proved how successful C&D waste recycling can be. Once the City of Los Angeles
agreed to fund the recovery program through escalated tipping fees, the Districts launched a pilot
3 Composition percentages are from CIWMB Interim Database, August 4, 1993,
4 Based upon the Board of Equalization's 12.068,712 tons of solid %N aste reported as disposed
in Los Angeles County in 1994.
14 chiquitampd
program with the initial goal of recovering up to half of the 1,000 tons per day of debris brought to
the landfill. By last December, earthquake debris material recovery had reached 94,5 percent.5
Citywide, at the end of the program in May 1995, over 80 percent of every ton collected off the
streets was recycled. Similar recovery rates for the routine generation of C&D waste and other inert
materials can be achieved if C&D recycling plans and programs are implemented.
The four County -owned landfills have not yet implemented permanent mixed inert or mixed
C&D recycling facilities to their landfills, nor made any policy recommendations or commitments to
do so as part of a plan to extend landfill capacity. The County LEA has not indicated any policy of
making the installation of such facilities at public or private landfills under their jurisdiction a priority
when reviewing permit applications. The DEIR has not evaluated the impact of instituting such
activities at public or private landfills in Los Angeles County on future disposal capacity need.
Furthermore, the DEIR ignores over 33.65 million tons of remaining inert landfill capacity available
in Los Angeles County from four additional inert landfills that could be utilized if inerts were banned
from Class III landfills (as has occurred in other jurisdictions).
B. WOOD
In 1994, the calculation using CIWMB data indicates a total of 1,062,047 tons of
wood were landfilled as part of the MSW generated in the County. Wood is both reusable and
recyclable. Pallets, for example, can be repaired and reused. Pallets, lumber, and other wood that
is not reusable is recyclable by processing. This is discussed in Appendix A.
The DEIR has not evaluated the impact of encouraging wood reuse or recycling activities
through expansion of County landfill wood recycling practices, economic development actions to
stimulate wood reuse/refurbishing companies, initiatives to increase export to Mexico of reusable
wood, donation programs that provide wood to non-profit agencies such as school woodshop
5 Janet Coke, "County Initiates Earthquake Debris Recycling Program,' World Wastes,
March 1995.
15 chiquita.wpd
programs, landfill bans, or tip fee incentives.
C. YARD WASTE
In 1994, the calculation from the CfVdMB database indicates a total of 1,532,726 tons
of yard waste (also referred to as yard trimmings or green waste) were disposed of in landfills from
MSW generated in the County. This tonnage should not be included in calculations of future disposal
requirements because yard waste materials are very easily recycled and needed to meet the diversion
goals. Much of this material which is shredded for recycling is being landfilled as "alternative daily
cover," which does not extend landfill life as does the use of synthetic or tarp covers discussed in
Section IV.
The DEIR has failed to evaluate the impact of instituting a wide range of yard waste diversion
activities, including but not limited for landfill bans, such as those instituted in many states and in San
Diego County, or the potential for increasing composting activities (versus ADC activities) by using
public landfill property for composting sites and instituting a "tip fee levelization" structure as
proposed for rail haul to cover the cost of building such facilities at County landfills:
D. WHITE GOODS
White goods are large appliances such as dishwashers, refrigerators, etc. These
materials contain high-quality steel and are recyclable through existing scrap industries. In 1994, the
CIWMB database calculation indicates a total of 36,206 tons of white goods were landfilled from
MSW generated in the County., This tonnage should be deleted from future solid waste disposal
projections.
AB 1760 lays out requirements for appropriate handling/processing of a wide range of
household appliances before landfilling of these items is allowed. The DEIR does not address the
impact of this legislation on disposal costs, nor the potential for recycling almost all of these items
16 chiquita.wpd
once segregated and evaluated for compliance with AB 1760.
E. TIRES AND RUBBER
Under California State law, whole tires are banned from landfill disposal. Tires are
recyclable, and also pose problems for landfill compaction and cover because they are resilient. As
a result of the landfill ban on whole tires, shredding operations have been developed. However, the
shredded tires are still being landfilled. In 1994, the calculation indicates a total of 168,962 tons of
tires and rubber were disposed of from the MSW generated in the County:
The DEIR does not evaluate the increased cost of landfilling tires as a result of the
requirement for shredding/cutting tires, nor the potential for spurring end-use markets through the
use of County economic incentives to build facilities (through such mechanisms as the County RMDZ
program), nor the impact of banning tires altogether from County landfills. It also does not evaluate
the impact of an alternative that creates markets for recycled rubber through County purchasing
decisions.
F. CROP RESIDUES
This material is recyclable through composting either alone or along with other organic
wastes. In 1994, the calculation using the CIWMB database indicates a total of 2,088 tons of crop
residues were landfilled from the MSW generated in the County. The relatively small amount of crop
residues on the farm, generally by harrowing under the material left in the field after harvest (direct
land application), composting on site, or open burning. None of the 1990 tonnage should be included
in future projects of disposal capacity requirements.
17 chiquitampd
G. MANURE
This material is also recyclable through composting. In 1994, the CIVVNM database
calculation indicates a total of 60,344 tons of manure were landfilled from MSW generated in the
County. Farms, feed lots, and other sources of manures generally manage the waste by composting
on site. Some generators, however, have disposed of this waste in the past.
H. BIOSOLIDS
"Biosolids" refers to sewage sludge, the high moisture content organic solids that
remain after wastewater treatment.. In 1994, the calculation indicates a total of 12,069 tons of sewage
sludge were landfilled from waste generated in the County, This material is recyclable through direct
land application or composting, and should not be included in projections of future disposal capacity
needs.
The calculation of 12,069 TPY based on the CIWMB database does not appear to include
biosolids from County Sanitation District operations disposed of at Puente Hills. The DEIR is
deficient in that it does not evaluate the impact of stopping the County Sanitation District practice
of landfilling a substantial portion of County biosolids rather than instituting a policy of 100 percent
land application and composting.
Biosolids generated by the City of Los Angeles' Hyperion Treatment Plant are co -composted
with yard wastes to produce TOPGRO, among other beneficial uses. By maintaining contracts with
a variety of end-users, the City of Los Angeles Biosolids Management Program has managed to
sustain 100 percent beneficial reuse despite inclement weather, riots, earthquakes, fires and freeway
traffic jams,'
6 "Proactive Biosolids Management,' Biocycle, December 1994.
18 chiquita.Nvpd
I. MSW GENERATED OUTSIDE THE COUNTY
The Solid Waste Quarterly Disposal Quantity Report Summary for the first quarter
of 1995 drafted by the County Department of Public Works shows a total of 3,011,713 tons of MSW
was disposed of in County landfills (out of 3,679,729 delivered to those facilities) during the first
quarter. Of that total, 144,956 tons, or approximately 1,883 tons per day, originated outside Los
Angeles County. This is 4.8 percent of all solid waste landfilled in the County. The CIWMB reports
that the first quarter returns are generally 23 percent of the annual disposal, so the amount of out -of -
County was disposed of at County landfills is approximately 5 percent of the total annual amount
disposed. The Report does not indicate export of MSW generated in Los Angeles County that was
exported to other jurisdictions for disposal during the same time period.
19 chiquita.wpd
IV. LIMITED CONSIDERATION OF ALTERNATIVES TO THE PROPOSED
PROJECT
The DEIR section 1.38 Alternatives only considers alternative landfill sites and a no action
alternative. However, there are alternatives that, if implemented by the County, would decrease or
eliminate the need for additional disposal capacity. Diversion alternatives were avoided in the DEIR
by assuming 50 percent diversion rate for the County. This does not constitute a real consideration
of alternatives to the Elsmere landfill. The Waste Reduction and Alternatives Section on pages 1-49
states that "these methods cannot offset the ultimate need for additional landfill capacity," but does
not offer data or justification for this conclusion.
A. LANDFILL OPERATIONS
Some alternatives are addressed (VII -41) that would conserve the existing landfill
capacity in the County by modifying the way landfills are operated . Additional techniques are
available commercially and others are in development that conserve landfill space and thereby reduce
the need for siting new landfills. A CIWMB-funded study released in May 1995 noted the value of
utilizing these techniques. These techniques include:
Chemical or Foam Cover
Using the conventional daily cover of six inches of dirt consumes about 26
percent of a landfill's capacity'. In the case of the currently operating landfills in the County, this
accounts for 16,949 cubic yards of wasted landfill airspace daily', based on the Draft Solid Waste
Quarterly Disposal Quantity Reporting Summary prepared by the Los Angeles Department of Public
Works for the first quarter of 1995. In-place compacted density of cover soil is roughly 2000 pounds
per cubic yard, so the cover materials represent roughly 10,000 tons per day of MSW capacity. This
7 Darlene Snow, "Alternative Daily Cover Material," M.SWMnngifement,. September/October
1994.
8 Assumes. 39,461 TPD disposed daily at 1,190 pounds per cubicyard.
20 chiquita.wpd
approach may over -calculate cover soil airspace requirements slightly, because of the higher -than -
average compaction resulting from the weight of overlying layers of waste in extremely deep canyon
landfills.
Use of alternative daily covers, such as foam, have proven to save landfill space, reduce wear
and tear on equipment, cut down on dirt hauling time, and reduce the costs of daily cover operations.
With Sanifoam, an alternative daily cover produced by 3M, original cover thickness usually falls
between 1-2 inches. Once the material is sprayed it "cures" after about two minutes into a
waterproof, noncombustible, impermeable shell. When refuse is compacted onto the cover the next
day, the space savings increase even further as the foam crushes down to one-tenth to one -fifteenth
its original height'..
Since January 1993, the North Central Iowa Regional Landfill has been using an alternative
daily cover material composed of shredded old newspapers soaked in a proprietary mixture. The
cover material is sprayed onto the open face with a hydro seeder until the cover is about 1/8 to 1/4
inch thick.. In addition to saving close to 25 percent of the landfill capacity, the shredded newspaper
mixture costs $.10 less per square yard when compared with dirt10.
2. Tarp Intermediate Cover
Tarps are another form of alternative daily cover that can provide dramatic
savings in landfill airspace. Although tarps cost considerably more per square foot than dirt, they are
more cost-efficient due to their reusability.
' Randy Woods, "Alternative Daily Cover: Stronger Than Dirt?," Wasie Age, November
1994.
10 Darlene Snow, "Alternative Daily Cover Material;' A4SWManagemenr, Septembcr/October
1994.
21 chiquitampd
Most landfill tarps are non -woven polyethylene or polypropylene and are equipped with D -
ring attachments that can be hooked to landfill equipment for placement and removal. Tarps are not
fit for use on landfills with frequent snow or excessive winds; however, neither of these conditions
are a problem in Los Angeles County,
The Petersburg Landfill in Central Virginia now uses tarps for daily cover. A dirt cover is
applied to the active cells only once a week or once every two weeks. The City of Petersburg
estimates $200,000 per year is saved on the 22,000 cubic yards of dirt it was paying to have delivered
for daily cover. Landfill managers have also noticed substantial savings in handling time - about three
to four hours - previously needed for the loader to move dirt. It is estimated that use of the tarp is
saving 20 percent of the landfill capacity"
3. Leachate Recirculation to Accelerate Decomposition
The practice of leachate recirculation in landfills has proven to provide
numerous benefits, including attenuation of leachate organic strength and quantity, increased rate
of landfill stabilization, immobilization of metals leached from landfilled materials, and improved
landfill settling and compaction rates.
The increased moisture content from recirculating leachate promotes biological activity,
resulting in faster decomposition of organic materials and a concomitant increase in landfill gas
production. The loss of solids from decomposition in the landfill consolidates the landfilled material
and speeds the resultant settling,
Laboratory studies of leachate recirculation have shown that decomposition periods can be
reduced to 18 to 36 months, as opposed to the 20- to 30 -year period normally associated with refuse
Darlene Snow, `Altemativc Daily Cover Material;'MSWManogement, Septembcr/October
1994.
22 chiquita.wpd
decomposition". Although these studies are done on small-scale models and field tests do not reveal
such dramatic increases in stabilization rates, leachate recirculation has proven to have a considerable
effect on waste decomposition in landfills. At the Alachua County Southwest Landfill in Florida, it
was assessed that in cells with leachate recirculation the half --life of the waste's biodegradable mass
was decreased to 3 to 5 years; this compares to a half-life of 10 or more years for the waste in
untreated sections of the landfill":
4. Shredding and Biostabilization
An evolving concept of landfilling, stabilized placement or biostabilization, is
gaining significant interest as a means to substantially conserve landfill space, particularly where
disposal capacity is at a premium and conservation of natural soils is important. In the biostabilization
process, following the removal of recyclables, solid waste to be landfilled is shredded and the
moisture content is adjusted (preferably to between 40 to 60 percent). The shredded waste is then
aerated for a period of 60 to 90 days. Following the aeration period, the waste is compacted with
standard landfill compaction equipment. Experience at an operating facility in Albany, New York
indicates that after bio stabilization, 50 to 100 percent more refuse can be placed in the landfill cell
when compared with conventional landfilling."
5. Baling
Baling solid waste prior to landfill disposal is another technique that has proven
to conserve landfill space. By operating the landfill as a balefill, on average, 45 percent greater
compaction will be achieved when compared with conventional compaction methods. Typical bales
12 Kevin O'Leary, "Development of Leachate Disposal Processes," Waste Age, July 1995.,
13 T. Townsend, W. Miller; R. Bishop, and J. brier, "Combining Systems for Leachate
Recirculation and Landfill Gas Collection,"So/id Waste Technologies, July/August 1994.
14 David L. Hansen, "Biostabilization of Landfill Waste," Waste Age, June 1995.
23 chiquita.wpd
(3' x 5' x 4') of MSW weigh up to 3,000 pounds, and a well-designed and operated balefill may
consume less than half of the equivalent active fill or cell area as a conventional landfill operation for
the same tonnage of waste and the same height of fill.
At the Jonesboro Landfill, in Craighead County, Arkansas, an initial density of 1,500 pounds
per cubic yard is achieved by feeding the waste through a baler prior to disposal. Further (secondary)
compaction will occur as lifts of waste are layered upon each other. Fresh Kills Landfill, in New
York, reports an in-place density of 1,800 pounds per cubic yard after settlement-"
6. Landfill Reclamation (Mining)
Landfill reclamation, or landfill mining, is the excavation and mechanical
processing of previously landfilled material to recover materials or landfill airspace, reduce the size
of the landfill, or transfer material from an unlined to a lined landfill.
An extensive evaluation of a landfill mining site was performed in Collier County; Florida by
the U.S. EPA's Risk Reduction Engineering Laboratory. During a two-week demonstration period
in 1992, County staff mechanically processed 292 tons of excavated material through coarse and fine
screens, an air knife/de-stoner, and magnetic separators into nine fractions. Two of these fractions --
a soil fraction and a ferrous metal fraction -- were determined to be revisable. The recovery of ferrous
metals averaged about 75 percent with a purity of 82 percent."
A reclamation project at the Frey Farm Landfill, in Lancaster, Pennsylvania, involves continual
hauling of the excavated waste to a neighboring WTE facility. The Lancaster County Solid Waste
Management Authority (LCSWMA) reports that revenues from the sale of electricity and recovered
ferrous metal offset operating costs of the landfill reclamation project and result in net revenues of
15 Anne Magnuson; "The Economics of Landfill Compaction,"MSWManagement,
November/December 1992.
16 John T. Aquino,. "Reclaiming Landfills; Amazing interest,' GYo.rte Age, February, 1994.
24 chiquitampd
$3.94 for every tons of reclaimed refuse delivered to the WTE facility. Additionally, the mining
operations are creating 2,500 cubic yards of vacant landfill space each week."
7. Incineration
Two sites currently operate in Los Angeles County and have consistently been
below the maximum contaminant levels mandated by the South Coast Air Quality Management
District. Page VII -45 of the DEIR indicates that this technology may be viable if the technology can
meet AQMD standards. It has and can continue to do so.
B. SOURCE REDUCTION
The DEIR assumes a 50 percent diversion rate for the MSW generated in Los Angeles
County. It is not specific on how this goal is reached and does not distinguish between source
reduction and recycling. The source reduction relies on policy initiatives followed up by goals and
specific programs. Consequently, implementation of source reduction efforts have lagged behind
development of recycling programs. As recycling matures, source reduction is rapidly coming to the
forefront of community efforts. Source reduction initiatives tend to be legislative and educational.
The County's Solid Waste Management Action Plan and other operative documents do not
place the County in a leadership role in source reduction. In fact, the Integrated Solid Waste
Management Plan for the County that is supposed to specify policies, goals and programs in source
reduction is not complete at this time. Therefore, the current policy is that which is enunciated in the
1988 Action Plan. This needs to be revised. Alternatives that the County could implement are listed
below:
17 John T. Aquino, "Landfill Reclamation Attracts Attention -and Questions," Waste Age,
December 1994.
25 chiquita.wpd
I . County Policy Options
• Variable rate generator fees for Residences - volume based
• Variable rate fees for Commercial establishments - weight based
• Bans on landfill acceptance of specific materials, including inert materials,
wood, yard waste, white goods, tires, crop residues, manure and sewage
sludge, including yard waste as alternative daily cover
• Actively develop, recommend and support state and federal efforts to
reduce packaging and other waste at the source.
2. County Tax on Commercial Generators
• High for establishments that don't report diversion
• Low for those that do report diversion
• Penalty for not making 50 percent
• Incentive for making 50 percent diversion and above
3. County Outreach Program to Promote Source Reduction
• Residential --backyard composting, grass mulching, buying information
• Commercial -- building management assistance, small establishment
cooperative approaches, hauler workshops
• Industrial -- waste exchanges, waste audit assistance, pollution prevention
activities
4. County Enforced Reporting and Enforcement
5. County Programs for Market Development and Purchasing.
26 chiquita.wpd
APPENDIX A
chiquita.wpd
APPENDIX A
DIVERSION ALTERNATIVES
The DEIR deficiencies in considering the potential of waste diversion approaches in reducing waste
requireing disposal are discussed in Section II. In this Appendix, examples of some communities'
successes with waste diversion are outlined, and the technologies, services and facilities needed to
accomplish the recovery, recycling, and beneficial reuse of components of the waste stream are
outlined.
A. ESTIMATES OF MAXIMUM DIVERSION POTENTIAL
The DEIR makes more than eleven refernces to a lack of confidence in
achievement of 50 percent diversion goals, primarily relying on quotes from the same Los Angeles
County agency that projected in earlier Action Plan documents that 27 percent by the year 2000 was
the maximum feasible diversion scenario and that 10 percent was a more likely scenario. It also
ignores the fact that diversion trend lines throughout California and the rest of the United States
continue to grow as localities institute programs to meet 1995 and year 2000 goals. Listed below are
just a few of the examples which demonstrate that many localities are already achieving over 30
percent diversion, either locality -wide or in selected portions of the locality which have implemented
expanded diversion programs. Furthermore, the City of Seattle, referenced in the EIR as being the
only major metropolitan area with a documented diversion rate of 36 percent, by the end of 1994 had
over 45 percent.
1„ City of Los Angeles
The Citywide AB 939 goal for 1995 is 37 percent. The goal in the Cit Solid Waste
Management Plan is 70 percent by 2020, The City had already achieved close to 22 percent diversion
in 1990, primarily through commercial and business diversion, and is expected to achieve rates in the
mid -30 percent in 1995.
A-1 chiquita. wpd
The Bureau of Sanitation provides refuse and recycling services to 720,000 households, about
one-half of the City's residential population. In addition to private recycling by residents through
buyback centers and drop-off centers, the Bureau initiated a curbside recycling program aas part of
its long range strategy for landfill alternatives in 1990. In 1990 this program diversted approximately
1 percent of the Bureau served waste stream. By May 1995 this program, plus curbside composting
and other diversion activities, diverted 26 percent of the Bureau served waste stream. Curbside
recyclables were being collected from all 720,000 households an the curbside yard trimmings program
was serving 452,000 households. The program continues to be expanded in 1995, with a32 percent
diversion rate expected to be achieved by December 1995 for Bureau served households. As part of
the expansion process, an RFP for residential mixed paper was issued in summer 1995.
The average diversion rate for all households in Los Angeles which are fully served by both
the curbside and composting programs was 39.28 percent in April 1995, The recycling rate has
achieved 42.9 percent in one of the City's five districts, West Valley; where all households have
curbside and composting services. In the West Los Angeles District, portions of the District with
both curbside and composting services have achieved over 50 percent.
The above has been accomplished to date with a voluntary program and without volume based
pricing incentives for the residential sector_ Expansion of programs for both the residential and
commercial sector are continuing as noted in the City's AB 939 plan.
2. Madison, Wisconsin
Madison, Wisconsin, a college community of 191,000 people, accomplishes over 50
percent diversion through City -operated curbside collection of glass, plastic, and metal containers;
newspaper, magazines, and cardboard. Crubside-collected materials are processed at the Dane
County materials recovery facility. Recyclable metal wastes (such as white goods and bicycles) are
recovered from the bulk waste stream and recycled through scrap dealers. Yard waste and brush are
also collected at curbside and delivered to the Dane County composting facility. Additionally, the
A-2 chiquitampd
City also sponsors a backyard composting program -- a source reduction technique. A small fraction
of the City's waste is also sent to a mixed waste composting facility in Columbia County, Wisconsin.
The City plans to add mixed paper to their curbside collection this year,
3. Seattle, Washington
The City of Seattle, Washington has a population of 530,000 and diverted over 42
percent of the waste stream as of December 1994. Their goal is to divert 60 percent by 1998. The
recycling/diversion efforts of the city are widely recognized for pioneering such techniques as the pay -
per -container approach that reinforces waste reduction and recycling practices. Residents sign up
for a 19 -gallon, 32 -gallon, or a micro can (10 -gallon) solid waste collection service; their monthly
charges for both recycling curbside collection and solid waste collection are based on the disposal
container size selected. If the residents exceed their can size, a prepaid trash sticker is available. By
requiring residents to pay for service based on the amount disposed, residents are encouraged to
reduce the amount of waste generated and to recycle as much as possible. The Seattle Solid Waste
Utility manages collection and disposal of waste in the City as an Enterprise Fund. Fees collected,
revenues from sale of recovered materials, and State and regional grant funds must support the
operating activities of the Utility. The Enterprise Fund approach also encourages diversion of
material from disposal, thus keeping costs to residents as low as possible while freeing up funds for
services. Los Angeles County has a policy of operating the waste system as an Enterprise Fund. But
does not actually do so.
4. New York City
New York City has conducted an experiment with intensive recycling actions in one
dense neighborhood of the City, in which larger portions of the waste stream, such as mixed paper
and food waste, are targeted for curbside collection, Areas served by this program have consistently
achieveed diversion rates in the mid -30 percent and have peaked at over 40 percent, despite the
density of the neighborhoods and preponderance of rental units.
A-3 chiquitampd
5. San Diego County
San Diego County's achievement of a more than 40 percent recycling rate by June
1994 is due largely to the banning of selected materials from County Landfills.
6. Sonoma County
Sonoma County, California has achieved a 39 percent diversion rate of landfilled waste
by June 1995, compared to a 15 percent diversion rate in 1990. While the County population
increased by 30,000 people since 1990, annual tonnage disposed at landfills dropped by 120,000 tons
in the same time period.
7. Santa Clara County
As the County of Santa Clara continues to expand its diversion programs through five
districts, several district recycling rates had exceeded 30 percent by April 1995 and one area, Los
Altos, had exceeded by 42 percent.
B. COLLECTION
The techniques used to collect MSW have an impact on the diversion potential. Once
recyclable materials are mixed in with materials that are potential contaminants, they are harder to
recover. For example, when food waste from a supermarket is placed in the same container as old
corrugated containers (OCC) then collected in the same truck, the OCC is contaminated by the food
and is less recyclable. The DEIR examined no alternatives that provide for modification of collection
techniques. Techniques which have potential to increase diversion include the following:
A-4 chiquitampd
1, Intensive Residential Curbside Collection
This approach adds residential mixed paper (junk mail, OCC, boxboard, phone books,
kraft bags, and magazines and catalogues) and textiles to the standard set out and collection.
Separate set out and collection of yard waste, if not used, should be added. This alternative may be
coupled with new collection techniques such as the split container and truck system used in Visalia,
California; or the once per month collection of recyclables used in Seattle, Washington. Based on
a survey of 19 California programs (Resource Recycling, June 1995) the average household set out
189 pounds of mixed paper (excluding newspaper) in 1994. Based upon 2,989,552 households, the
addition of mixed paper to County -wide recycling collection, the additional diversion at this rate
would be an estimated 283,000 tons. Seattle, Washington averages over 100 pounds per family
higher in residential mixed paper collectionthan the 19 Californial programs. If an intensive program
such as Seattle's was implemented County -wide, an estimated 383,000 tons could be diverted. This
is only 10 percent of the total paper estimated disposed of in the County in 1994.
2. Wet -Dry Collection
This alternative collects "wet" garbage separately from "dry" trash. It is
applicable to both residential and commercial collection. Wet/Dry collection has application in both
the residential and commercial sectors. Applied to the residential sector, recovery well above the 50
percent level has been demonstrated. Santa Barbara County" conducted a pilot program with four
different collection schemes. The diversion rates ranged between 57 and 73 percent, with an average
of 65 percent_ The project recognized that high rainfall had increase yard waste; adjusting for this
factor, the average diversion was 58 percent.
Commercial collection of food waste from restaurants, supermarkets and other food service
establishments that are collected on a single route could be delivered to a composting facility, The
is The Santa Barbara County Pilot Waste Collection Project, Final Report„ April 1994.
A-5 chiquita.wpd
non-food waste from other commercial establishments such as offices could then be free of this
potential contamination and more easily recovered. For example, the waste from some office
buildings contains 90 percent paper. Without the addition of other materials during collection, waste
paper from offices is highly recoverable. There are many examples of high level commercial/industrial
waste diversion, ranging from 60 to 90 percent. These include major U.S. and California firms,
including ATT, IBM, Fetzer Vineyards and Transamerica Corporation.
3. Construction Waste
During construction projects, the general contractor provides a roll -off box that is
used for waste from all subcontractors. if the subcontractors had to remove their own waste or if the
general contractor provided separate containers, then the lumber from the carpenters; the gypsum
from the drywall contractor, the asphalt shingles from the roofer, and the other specialized materials
from individual trades would be separately collected and recyclable. This is currently being done by
a private firm in the St. Louis, Missouri metropolitan area and other cities in the United States.
4, Comprehensive Drop-off Centers
To augment other collection alternatives, a system of centers designed to accept all
types of waste and recyclable materials will divert additional material. These facilities accept reusable
items such as building materials and furniture, household hazardous waste (e.g., paint, batteries,
household cleaners), used oil, auto parts, appliances, yard waste and refuse. Reusable and recyclable
items could be accepted at no charge, while refuse requiring disposal could carry a small charge.
The City of Los Angeles in their Phase IV Report Solid Waste Management Policy Plan
projected a 70 percent diversion rate in the year 2020_ If the City along achieved 70 percent diversion
in 2003, the County's disposal requirement (shown in Table 7.1 of the DFIR at 30,293 tons per day)
A-6 chiquita.wpd
would drop by 4,02919 tons per day or 13.3 percent. If all the jurisdictions in the County achieved
70 percent diversion, the County's disposal requirement in 2013 would drop by 12,117 tons per day
or 40 percent. While 50 percent diversion is considered difficult to achieve in the DEIR, there are
jurisdictions across the U.S.. that are achieving more than 50 percent diversion today and others
rapidly approaching this level.
C. PROCESSING FOR DIVERSION
1. Materials Recovery Facilities (MRFs)
Materials Recovery Facilities (MRFs) recover materials from the waste stream
by separating them into marketable commodities. For example, glass is separated from other
containers and contaminants, then sorted by color (amber, green and clear). The product is a clean,
color -sorted glass that meets the glass manufacturing industry's specifications for glass cullet used
to manufacture new glass products. The processes used by a MRF to accomplish these separations
can be low-tech (relying primarily on hand -sorting) or high-tech (utilizing mechanical equipment as
well as hand -sorting as needed). The materials processed and marketed by MRFs generally include
all types of containers (glass, aluminum and steel), various types and grades of paper including
newsprint, office paper, mixed paper, corrugated, etc.; and plastics (usually only PET and HDPE
although other resins may be recovered).
The DEIR states, in table 7-4, that "alternatives determined to be infeasible per 15126(d) of
CEQA guidelines." However, the DEIR has provided no backup documentation to prove this
assertion, nor to demonstrate that capacity is not increasing at a rate that will ensure diversion rates
of 50 percent and higher by the year 2000 and beyond. This lack of analysis regarding facility
capacity required to ensure diversion alternatives occurs despite the fact that several public
19 The Solid ]Masre Management Action Plan, approved by the Los Angeles County Board of
Supervisors April 5, 1988, shoNvs 1,966,000 tons per year requiring disposal at 70 percent
recycling.
A-7 chiquitampd
documents exist to provide information about diversion capacity within the County and available for
County use. These documents include, but are not limited to: The SRREs and non -disposal facility
elements prepared by all jurisdictions in the County, including the unincorporated area of the County;
recycling industry organizations and publications which regularly prepare directories of recycling
facilities that buy-back and process paper, textiles, metal, plastic, etc.; surveys of solid waste facilities
such as Government Advisory Associates publishes an annual listing of multi -material MRFs and
mixed waste processing facilities, and the lists prepared by the CIWMB; and information included in
various County publications regarding permits for solid waste facilities with recycling capacity. There
are clearly more diversion facilities in Los Angeles County than there are disposal facilities. In light
of the fact that location and capacity of these facilities greatly impacts on the potential for diversion
alternatives, it is essential that the DEIR investigate and document the status of diversion processing
capacity available to the County.
2. Composting Facilities
Composting is defined as the bacterial decomposition of organic materials. All of the
composting technologies commercially available today rely on aerobic decomposition (that is, utilizing
bacteria that live in the presence of oxygen). Anaerobic digestion of waste stream materials
(composting that utilizes organisms existing in an oxygen -free environment) is still in development.
Composting reduces the volume of incoming organic material by about 50 percent, through the loss
of moisture and carbon dioxide during processing. The high temperatures generated by bacterial
activity serve to kill pathogens, and most seeds and spores. Processing can be relatively low-tech,
such as windrow piles that are turned occasionally to maintain proper moisture and temperature for
bacterial activity, to high-tech, mechanized equipment used to compost mixed MSW. All of the
technologies discussed below are focused on processing quantities diverted from the waste stream,
as opposed to home composting approaches. Home composting can divert residential yard and food
wastes (except meat and dairy waste). Composting, but its nature, produces odors which must be
controlled.
A -A chiquitampd
Markets for compost derived from components of the MSW stream are still developing. The
industries and farms that can utilize these materials in significant amounts are tentative about risking
their livelihood on a relatively unfamiliar product. Considerable education efforts, demonstration
programs, and scientific studies are still needed to open these markets to the very large amount of
materials composting is expected to divert from the waste stream.
a. Yard Waste
Yard waste materials are recyclable. In the City of Los Angeles, yard
trimmings from the curbside collection program are used by San Joaquin Composting (SJC) as
bulking agents for composting the City's biosolids (see below) at SJC's facility in Lost Hills,
California. This City program is known as Full Cycle Recycle (FCR). FCR presently diverts all
biosolids generated by the City of Los Angeles, and all yard trimmings collected at curbside. As of
the beginning of 1995, about 250 tons per day were delivered to SJC, and the remaining material was
either composted elsewhere or used as mulch. As the curbside collection program continues to
expand, all future yard trimmings collections will be incorporated into the FCR program, thus
diverting all residential yard waste generated in the City from disposal. The FCR plan calls for the
creation of local facilities that will play a major role by serving as yard trimming drop-off and transfer
to SJC sites, and, after processing, centers for bagging and distributing the product, "TOPGRO."
TOPGRO is presently bagged at Los Hills facility and marketed by an SJC subsidiary, Organic
Supply, Inc, TOPGRO is sold by local outlets, such as Fedco membership department stores and
Armstrongs' -- The Home and Garden Place. The compost is also used by City agencies in
maintaining City -owned parks, gardens, and golf courses, and for facility landscaping.70
The green waste fraction of yard wastes (i.e., leaves, grass clippings, weeds, small prunings)
can be composted alone or in conjunction with other waste materials, such as biosolids, food wastes,
contaminated paper that cannot be recovered otherwise (such as disposable diapers), and similar
20 Biocycle, "Co -Composting in Los Angeles Optimizes Resource Management;' December
1994.
A-9 chiquita wpd
organic fractions of the waste stream. An estimated 100 compost facilities are in operation in
California as of May 1995.
Yard waste is also diverted from disposal through source reduction approaches, specifically,
the "don't bag it" method of leaving grass clippings on the lawn to provide nutrients and reduce
waste, and home composting. In Alameda County, California's's Master Composter program has
trained 39 Master Composters, who, in turn, have trained over 5,000 home composters in the County.
In 1993, 6,600 home compost bins were sold by the County program to homeowners. A follow-up
survey showed 94 percent of the recipients regularly used their bins. Previous survey work in
Alameda County demonstrated that each home compost bin diverts approximately 600 pounds of
compostables each year. Based on the participation rates, the County estimates that the 1993 bins
divert 1,800 tons from the County waste stream. San Diego County has established a Master
Composter demonstration center at Quail Botanical Gardens. The Master Composters trained at the
Center commit to 40 hours for teaching the knowledge and skills they have gained to others.'''
In addition to use as a bulking agent for composting, woody waste (i. e., tree limbs, branches,
brush) can be chipped and used as mulch or wood fuel (as discussed above), The Public Utilities
Commission's deregulation of the electric utility industry caused a number of wood waste -to -energy
plants to close in California as a result, the fuel market for wood chips is limited at the moment.
Because of a'medfly quarantine in Southern California, all yard trimmings have to be processed within
the quarantined area before they can be transported elsewhere, Chipping and composting interfere
with medfly reproduction.
Yard wastes lend themselves to low-tech composting operations, because the low nitrogen
content means relatively low potential for odors during the composting process. Some materials,
such as grass clippings, are high -nitrogen and must be handled carefully. Larger facilities may roof
over the composting area, the pads may be paved, and some facilities enclose the initial composting
21 Biocyc/e,"Mastering the Way to Home Composting,' January 1994,
A-10
chiquita.wpd
area to avoid problems, such as excessive moisture from precipitation, over -drying from.winds, or
materials blowing off-site. Each "improvement" to the system adds to the overall cost.
All yard waste materials (also called "green waste') must be diverted from disposal in
California. Composting is used to convert the bulk of this material into a usable soil amendment.
Compost can be used as mulch, or can amend clay or sandy soils to improve moisture retention and
friability. The market for this material is the same as the market for peat moss, including home
gardeners, landscapers, nurseries, potting soil manufacturers, etc. .
Some yard wastes, specifically woody materials such as brush and tree limbs, can be chipped
and sold as mulch or fuel.
b. Food Waste
Composting of food wastes is more problematic than yard waste, because of
the potential for generating odors and attracting birds, rodents, and insects. Consequently food waste
composting is generally carried out in enclosed vessels (in -vessel or static -pile systems) during the
first stages of decomposition. The later stages of decomposition can be carried out in windrow -type
operations as are used for yard wastes.
The product resulting from food waste composting is higher invaluable nutrients than yard
waste compost. The product can be utilized as fertilizer in addition to its soil amendment properties.
Because of the higher nutrient content, food waste compost has a higher market value.
C. Biosolids
Biosolids are also referred to as sewage sludge; this material is the solid
portion resulting from wastewater treatment. Properly conducted composting processes reduce the
pathogen contents to safe levels. The U.S. EPA has published regulations concerning composting
A -I I chiquita.wPd
(and land spreading) of biosolids (Clean Water Act, Part 503).. The Part 503 requirements specify
both the process parameters (time, temperature, moisture, etc.) And application limits depending on
the product quality..
Because of the high moisture content of the biosolids entering the compost process (usually
biosolids have been dewatered but are still 50 to 80 percent water) and the potential for odors,
biosolids composting is initially conducted in enclosed vessels. The nearly -completed compost can
mature in windrow piles.
Biosolids compost is, if made from uncontaminated feedstocks, a high quality soil amendment
and, if properly marketed, will sell easily. In 1994 there were 201 operating biosolids composting
facilities in the U.S. and another 117 under development.'-'- Of the total 318, a number of commercial
biosolids compost products are successfully marketed, including Philadelphia's EarthGro and
Maryland Environment Service's COMPRO, which sells in bulk to developers for $17 per ton and
is bagged for consumer sales.
The City of Los Angeles operates the TOPGRO program discussed earlier, in addition,
Wheelabrator (Biogro) has proposed a facility with capacity for 500 TPD biosolids and 1,000 TPD
other organics. This facility is planned for Antelope Valley.
d. Combination Feedstocks (including manure)
One example of combined feedstock approaches is being implemented at the
Zoo in Griffith Park. The Griffith Park Composting Project, undertaken by the City of Los Angeles
Biosolids Management Division with the Departments of Public Works and Recreation and Parks,
will compost Zoo manure with biosolids and green trimmings from the park. If the current
demonstration project is successful, a permanent facility will be built, The compost will be sold as
22 1994 Biocycle Biosolids Sun cy, Biocycle H4 gazine, Dccembcr 1994.
A-12 chi quita.wpd
a specialty product under the TOPGRO label:'-'
Combining feedstocks requires the compost processor to tailor the facility design, operations
and equipment to the needs of the more problematic materials, such as manure. Enclosed buildings,
compost vessels, and process air cleaning equipment (to reduce odor emissions) are all needed to
reduce environmental impacts of these facilities. Combining feedstocks, however, allows the operator
to "design" the end product to meet the specifications of a particular market, including balancing
nutrient content, moisture, degree of stabilization, and particle size.
e. Mixed MSW
While there are 17 facilities operating in the U.S., mixed waste composting is
still in the development stage. Most facilities operate at a small scale (less than 200 tons per day) in
order to allow strict control of the waste entering the system. However, the FERST facility in
Baltimore, Maryland operates at 400 to 700 TPD. The systems used are high-tech; and in most
approaches, the waste must be pre-processed to remove potential contaminants (glass, plastics and
other inerts, and toxic items such as batteries) so that the resultant compost is low in chemical
contaminants.
The markets for mixed MSW compost have so far been limited. While the mixed waste
composting process can result in a product that meets the EPA's Part 503 standards for biosolids
compost, not all of the operating facilities are successfully doing so. Both product quality and market
development is needed. However, ti should be noted that the 150 TPD Sevier County, Tennessee
facility has been successfully marketing its product to agricultural and horticultural users since 1992.
23 Reba Fabrikant and Ray Kearney, "Co -Composting in Los Angeles Optimizes Resource
Management," Biocycle, December 1994.
A-13 chiquita. wpd
4. Construction and Demolition Waste Facilities
With construction and demolition (C&D) waste amounting to as much as 30
percent of municipal solid waste, diversion through C&D recovery operations conserves large
amounts of landfill space and adds years of useful life to landfill facilities. The City of Los Angeles
calculates that nearly 15 percent of the solid waste stream is C&D waste. 1n some jurisdictions, C&D
waste represents almost half of the total waste stream 24
The three basic categories of recoverable materials within C&D waste are inert materials,
shredded wood products, and ferrous metal. Recovered inert materials, such as asphalt, concrete,
dirt, rock and brick, are used for land reclamation, landfill final cover, fill for roads and airports,
embankments, road base and subbase, aggregate for filter layers in landfills, French drains and bridge
abutments, and asphaltic concrete. Uses for shredded wood include landfill cover; boiler fuel, animal
bedding, composting bulking medium, pulp mill feedstock, and raw material for particle board.
Recovered ferrous metals are used in remanufactured steel.
There are two basic types of facilities that process C&D materials. The first type accepts only
clean loads of single material such as concrete, asphalt, or wood. Processing usually includes size
reduction with a hammermill or shredder, followed by sizing through a trommel screen or vibrating
deck screen. Some manual sorting may be required to ensure the highest possible quality in the end
product.
The second type of facility processes mixed C&D material. The material is brought to a
tipping area, usually in a dump truck or roll -off box. Large pieces of materials, such as concrete,
wood and metal, are pulled from the pile for processing. The remaining materials are fed into a
mechanical processing system.
24 Business Recycling and Waste Reduction Guide, the County of San Bernardino Solid Waste
Management Department and the Cities of San Bernardino County.
A,14 chiquita.wpd
The steps and equipment involved in mechanical separation and size reduction of C&D waste
are generally very similar. Because many systems contain mobile equipment, the configuration of the
machinery may be revised as characteristics of the feed and products change. Processing systems
typically use trommel, disc or vibrating flat-bed screens to separate rock and soil. Density separation
(e.g., pneumatic or hydraulic sink/float operations( is then used to divert wood scrap from heavier
fractions. After wood scrap is size reduced through a hammermill or grinder, the material is often
subjected to magnetic separation to remove the metal fraction.
Depending on the incoming waste stream; C&D processing facilities can range in size from
under 50 tons per day to well over 2,500 tons per day. Cyclean, Inc., an asphalt recovery plant in Los
Angeles, has kept over a million tons of asphalt out of the landfill in the last seven years and has saved
the city $10 million 21 Cyclean uses a microwave technology to make hot mix from 100 percent
recycled asphalt. In addition to old pavement, crumb rubber from old tires can easily be incorporated
into the Cyclean asphalt. The Cyclean product is sold at a discounted rate to the City of Los Angeles.
As mentioned in Section IIIA, the diversion potential of CRD recovery operations was well
demonstrated in the 94.5 percent recovery rate experienced after the Northridge earthquake.. Within
a month of issuing a contract, a C&D waste processing line was in place at the landfill. From October
1994 through March 1995, the program diverted over 47,437 tons of dirt and 41,873 tons of concrete
from landfill disposal,"
Pallets and dimension lumber are also reusable. A survey completed by Pallet Profile Weekly
in December 1993 revealed that 70 percent of all pallets received for recycling are repaired for resale.
Only one percent of the pallets are disposed in landfills.'-' The remainder of the pallets are dismantled
for repair supplies, or ground into chips for use as boiler fuel, mulch, animal bedding, or particle
25 "Paving with Recycled Asphalt," Biocycle, September 1994.
26 Janet E. Coke,"Recycling Program Diverts Debris from Earthquake Cleanup,' Public
Works, June 1995.
�7 Roger Guttentag,"Making Recoven- Pallet -able," Resource Recycling, November 1994.
A-15 chiquitampd
board furnishings. Guadalupe Landfill, in San Jose, California, has taken an innovative approach to
managing the high percentage of redwood materials it receives from demolition projects. New World
Furniture, an affiliated company, separates and reprocesses the redwood material, then an on-site
carpenter re -works the wood to create home and garden items. The company grinds the unsuitable
material to a 2 -inch minus size, and markets this redwood mulch through Valley's Pride Organics,
a Guadalupe Landfill division. In Portland, Oregon, the number of wood processing facilities jumped
from three to eleven in 1990. Currently, recycling facilities in the area handle 100,000 tons of wood
each year.2B Most of these facilities are now charging nothing for clean, source -separated wood and
are selling it for $20.00 to $45.00 per ton.
5. Tire Recycling
As material recovery technologies continue to develop, many successful
methods of recycling used tires have emerged. In addition to being retreaded for resale, old tires have
been successfully diverted from landfill disposal through use as fitel, playground and athletic field
subbase, reroofing supplement, material for irrigation channels and other civil engineering
applications, road subbase, plastic filler, composting supplement to prevent excessive compaction,
and as an additive in modified asphalt, One recent estimate predicts that by the end of 1998, market
demand for used tires will exceed the amount generated annually.'-'
Because tires have a high Btu value, they can be processed into Tire Derived Fuel and burned
with other solid fuels, or they can be fed whole into cement kilns where they serve as fuel and as a
source of constituents needed in the manufacture of cement. A report to the legislature by the
California Integrated Waste Management Board (CIWMB), "Tires as a Fuel Supplement: Feasibility
Study," January 1992, notes that the consumption potential of burning shredded tires -- only in
cement kilns located in California -- is nearly 25 million tires per year, which exceeds the estimated
28 Randy Woods, "C&D Debris: Construction & Dismantling?," Waste Age, April 1994.
29 David Riggle, "Finding Markets for Scrap Tires," Biocycle, March 1994.
A-16 chiquita.x%,pd
21 million waste tires generated annually in California.
Processing tires into crumb rubber for use in asphalt and other applications has significant
potential. In particular, there is a huge, multi-billiondollar market for this material as a plastics filler.
Overseas markets for tire chips for processing into crumb rubber for new tires is growing as well.
BAS Recycling built a crumb rubber plant in San Bernardino, California, that has processed over 1.5
million tires to date.3° BAS received a $100,000 grant from the CIWIv1B to transform recycled
rubber into playground matting.
6. Waste -to -Energy Facilities (WTE)
Why are the waste -to -energy alternatives summarily dismissed in the DEIR
(Page VII -45)? There are currently two operating waste -to -energy (WTE) facilities in the County,
the City of Commerce and the City of Long Beach. These have a rated capacity of 1„760 TPD on
a seven day per week basis. In 1994, these facilities processed 1,686 TPD on a six-day basis. This
is 82 percent of the 2,053 TPD equivalent six-day per week capacity. While the 367 TPD of unused
capacity is not large by County standards, it represents a lost opportunity. Unlike landfill capacity,
WTE capacity not used each day is lost. Over the 15 year landfill planning period; a continuing
shortfall of 367 TPD adds up to over 2 million tons of lost capacity..
The permitted capacity of the two WTE facilities is 3,240 TPD on a seven-day basis.
Expansion of these facilities to the permitted capacity would add almost 500,000 tons of disposal
capacity per year. The County and the two cities should have policies and plans to utilize the two
facilities to the fullest extent possible.
WTE alternatives were not adequately addressed in the DEIR. The document notes that the
County abandoned its plans for WTE facilities due to concerns about air emissions. Why weren't the
30 Resource Recovery Report, July 1995.
A-17 chiquita.wpd
air emissions from the proposed landfill compared with those of WTE facilities? WTE facilities,
because of their smaller size (3,000 TPD is the largest in this country) can be located close to the
waste generation areas in the same manner as transfer stations. Both the City of Commerce and the
City of Long Beach facilities have this advantage. A fair comparison of air emission for a WTE
facility would include the operation of the transfer trucks to move waste to a remote landfill such as
Chiquita Canyon as well as the emissions generated at the transfer station.
The DEIR indicates that WTE alternative also were not considered because they "take
material away" from diversion and recycling. This is no more true of WTE facilities than it is of
landfills. Integrated waste management calls for planning a mix of alternatives. If Los Angeles
County plans for 70 percent diversion in the year 2020, there will still be 15,970 tons per day of waste
needing disposal based upon the DEIR. Four 3,000 TPD WTE facilities would reduce the need for
landfilling to approximately 7,000 tons per day, taking into account the seven-day per week operation
and 25 percent (by weight) ash generation of WTE facilities.
WTE facilities are constructed using two technologies, mass burn and refuse -derived fuel.
The mass burn WTE facilities accept mixed MSW and feed this material directly into the furnaces for
combustion. The heat generated is used to produce steam and electricity. This mass burn technology
is applied in the two WTE facilities located in the County as well as 66 other facilities in the U.S. that
are processing 22 million tons of MSW annually. There are 14 of these refuse -derived fuel (RDF)
production plants producing 4,713 tons of RDF per day currently operating." RDF facilities have
two stages. The first stage both removes non-combustible materials and shreds the combustible
portion to a uniform particle size. The shredded material, RDF, is sometimes compressed into pellets
for easier storage and handling. One advantage of this approach is that the fuel can be prepared in
a different location from where combustion occurs. RDF technology would allow location of
combustion power plants outside the Southern California airshed, eliminating concern about the
impact of WTE emissions in Los Angeles County.
31 Integrated Waste Services Association (IWSA), A9unicinol Waste Combustion Directory of
the UniteclStates, 1994.
A-18 chiquita wpd
E. RAIL HAUL
The DEIR provides a discussion of rail haul and cites projects being pursued by the
County Sanitation Districts (page 1-48). Rail haul is generally costed as a system including 1) remote
landfill tipping fees, 2) rail transport costs, and 3) transfer station (to load rail cars) costs. In the
comparison, in -County landfilling is costed at $20 per ton. Because this is the approximate cost of
landfilling in Los Angeles County, it must be assumed that the cost of transfer stations and transport
are not included.
The DEIR also states that waste transport by train also has impacts on noise levels, vibration,
traffic and air quality unlike those associated with truck transport (page 1-48). No explanation or
justification is provided..
The DEIR makes no analysis of the transfer station operations necessary and excludes these
costs in its comparison.
An advantage of rail haul not explored in the DEIR is the removal of truck travel from the
roads.. Montgomery County, Maryland added a mile rail haul to their waste -to -energy project to have
the benefit of reduced truck traffic. This was a higher cost alternative.
In a poll of 12 major waste -by -rail projects, revenues from rail haul of solid waste have risen
from $2 million in 1988 to $140 million at the end of 1994, representing a more than 40 percent
annual growth. WMX has been hauling 455,000 tons per year (TPY) of MSW from Seattle and
Island County, Washington to the Columbia Ridge Landfill in Arlington, Oregon, for more than four
years. On the other side ofthe.Columbia River, Rabanco transports about 1.6 to 1.9 million TPY of
MSW from Seattle and Snohomish County, Washington, to its Roosevelt Landfill in Klickitat County,
Oregon.
A -I) chiquitampd
Rabanco also hauls 150,000 TPY from the City and County of Napa, California to the Roosevelt
facility.32
Rail has also proven to be an efficient transporter of biosolids (sewage sludge). The
Epic/Longo project hauls 1,000 TPD from Newark, New Jersey, to farmland in Illinois and Texas33
Enviro-Gro transports partially dewatered sludge from New York City to a soil reconditioning site
in Arizona. New support has been included for the statement that rail haul would not secure landfill
capacity prior to projected shortfalls. The DEIR also fails to analyze or include truck haul to landfills
in adjacent counties including Orange, Riverside, San Bernardino and Kern that are seeking out of
county waste at extremely competitive rates..
32, Randy Woods, "Bye Design" Wave Age. Dccembcr 1994
33 Randy Wood, ibid.
A-20 chiquitampd
PAUL R. WATKINS (18991973)
DANA LATHAM 11898-19741
CHICAGO OFFICE
SEARS TO W ER;: SUITE 5800
CHICAGO, ILLINOIS 60606
TELEPHONE 13121 8767700
FAX (312) 993-9767
LONDON OFFICE
ONE ANGEL COURT
LONDONEC2R 7HJ ENGLAND
TELEPHONE + 44-171-374 4444
FAX + 44-171-374 4460
MOSCOW OFFICE
113/1 LENINS KY PROSPECT, SUITE C200
MOSCOW 117198 RUSSIA
TELEPHONE + 7.503 956.5555
FAX + 7.503 9565556
NEW JERSEY OFFICE
ONE NEWARK CENTER
NEWARK, NEW JERSEY 07101-3174
TELEPHONE (201) 6391234
FAX 1201) 6397298
LATHAM & WATKINS
ATTORNEYS AT LAW
633 WEST FIFTH STREET, SUITE 4000
LOS ANGELES, CALIFORNIA 90071-2007
TELEPHONE 1213] 485-1234
FAX 1213)891-8763
TLX 590773
ELN 62793268
CABLE ADDRESS LATHWAT
November 20, 1995
Los Angeles County Regional Planning Commission
320 West Temple Street, Room 170
Los Angeles, California 90012
NEW YORK OFFICE
885 THIRD AVENUE, SUITE 1000
NEW YORK, NEW YORK 10022-4802
TELEPHONE 1212) 906-1200
FAX (212) 751.4864
ORANGE COUNTY OFFICE
660 TOWN CENTER DRIVE, SUITE 2000
COSTA MESA, CALIFORNIA 92626.1925
TELEPHONE 1714) 5401235
FAX (7141 755.8290
SAN DIEGO OFFICE
701 •8- STREET, SUITE 2100
SAN DIEGO, CALIFORNIA 92101-6197
TELEPHONE (619) 236.1234
FAX (6191 696.7419
SAN FRANCISCO OFFICE
605 MONTGOMERY STREET, SUITE 1900
SAN FRANCISCO, CALIFORNIA 94111.2562
TELEPHONE (415) 391-0600
FAX 1415) 395-8095
WASHINGTON, D.C. OFFICE
1001 PENNSYLVANIA AVE., N.W., SUITE 1300
WASHINGTON, D.C. 20004.2505
TELEPHONE (202) 637-2200
FAX (202) 637-2201
Re: Applicant's Responses to Issues Raised in Public Hearings By
Opponents of the Proposed Chiquita Canyon Landfill and Resource
Recovery Project
Dear Commissioners:
This letter is written on behalf of our client, Laidlaw Waste Systems, Inc., to
respond to various issues raised at the August; 23 and September 26 public hearings by
opponents of Laidlaw's proposal to expand the existing landfill at Chiquita Canyon and to
construct and operate ancillary resource recovery facilities, including a materials recovery
facility, a recyclable household hazardous waste drop-off facility, and a composting facility
(the "Project").
Laidlaw has previously submitted written responses to comments raised at the
August 23 hearing, but for the Commission's convenience this package is a comprehensive
response which incorporates and supplements Laidlaw's previous submittal in light of the
additional comments raised at the September 26 hearing. For convenience, we list on the
index below the key issues raised at the public hearings, and we indicate where to find
Laidlaw's detailed response to each issue.
Upon considering the entire record before you -- the written and oral public
comments, Laidlaw's written and oral comments, your staff's report, the comments of the
Department of Public Works, and the Final EIR -- we believe it will be clear, that this project
is an environmentally -sound and neighborhood -friendly proposal that will help the County
take an important step toward achieving its important solid waste disposal goals.
LATHAM & WATKINS
Los Angeles County Regional Planning Commission
November 20, 1995
Page 2
For these reasons, we respectfully request that the Commission approve the
conditional use permit for this project.
Respectfully submitted,
Dale K. Neal
of LATHAM & WATKINS
Attachments
cc: Mr. James Hartl
Mr. John Schwarze
Mr. Richard Frazier
Charles Moore, Esq.
LATHAM & WATKINS
Los Angeles County Regional Planning Commission
November 20, 1995
Page 3
INDEX OF OPPOSITION ISSUES AND APPLICANT'S RESPONSES
Tab 1. The need for the Project.
Tab 2. Potential waste disposal and reduction alternatives.
Tab 3. Project impacts on water quality.
Tab 4. Project impacts on air quality.
Tab 5. Effects of landfill gas emissions: Toxicity and Odors.
Tab 6. Operation and reliability of the landfill's gas extraction system.
Tab 7. Project impacts on traffic.
Tab 8. Project impacts on Val Verde property values.
Tab 9. Compatibility of the landfill with current and planned nearby land uses.
Tab 10. Project noise impacts.
Tab 11. Project impacts on the health of the local community.
Tab 12. Laidlaw's regulatory compliance history at Chiquita Canyon.
Tab 13. Concerns regarding current landfill technology.
Tab 14. Concerns that Chiquita Canyon is exceeding its permitted flow rate into
the landfill gas flare.
Tab 15. Effectiveness of Laidlaw's practice of checking loads for unacceptable
wastes.
Tab 16. Concerns about landfill trash and mud on State Route 126.
Tab 17. Seismicity of the Chiquita Canyon Landfill and impacts of the
Northridge earthquake.
Tab 18. Laidlaw's worker safety policy.
Tab 19. Adequacy of Laidlaw's notice to the local community about the
proposed expansion.
Tab 20. Project impacts on riparian habitat associated with the least Bell's
vireo.
Tab 21. The handling of sludge in the composting facility.
Tab 22. The fairness of sludge disposal at Chiquita Canyon.
Tab 23. Breakdown of fees generated by the Project.
Tab 24. Necessity of DMS compliance.
DEFICIENCIES OF THE
CHIQUITA CANYON
DRAFT ENVIRONMENTAL IMPACT
REPORT
Project Alternatives
DEFICIENCIES OF THE CHIQUITA CANYON
DRAFT ENVIRONMENTAL IMPACT REPORT
TABLE OF CONTENTS
I. INTRODUCTION ... . , .. _ ..: ..... . ....... . ...... I
II. PROJECTION OF SOLID WASTE GENERATION IN
LOS ANGELES COUNTY ..... ....... . . . .........
....... 4
A.
CHANGING SOCIO-ECONOMIC CLIMATE .............
4
or Foam Cover .......................
1. Economic Restructuring .. . .. . .... . .. ......
. ..... 4
Tarp Intermediate Cover ............. . ..:.......
2. Changing Demographic Climate ...................
6
Leachate Recirculation to Accelerate
3. Changing Income Structure .. _ ....... I .... I——
, ... 7
Decomposition ...... :...... . .. . ..............
4. Implications for Waste Disposal Demand . ..........
_ .: 7
B.
WASTE COMPOSITION ......... ..................
. . : 8
C.
IN -COUNTY DISPOSAL CAPACITY; BASE YEAR
....... 9
D.
EXPORTAMPORT TONNAGES AND TRENDS ..........
10
E.
MSW GENERATION CALCULATIONS .............
. 10
F.
LANDFILL CAPACITY NEEDS ...... . . . . . . . . . ..
. ..... . I 1
III. INCLUSION
OF INAPPROPRIATE MATERIALS IN
CLASS III LANDFILLS . . ............. . ..................
14
A.
INERT MATERIALS ........... ........ .:........
14
B.
WOOD ...........................................
15
C.
YARD WASTE .. ...........................::.
:. 16
D.
WHITE GOODS .. ............:.:........... . .:
. .... 16
E.
TIRES AND RUBBER . ... ......................
, . , .. 17
F.
CROP RESIDUES .....:. ....... ....................
17
G.
MANURE ............. ...........................
18
H.
BIOSOLIDS ............................. ........
18
I.
MSW GENERATED OUTSIDE THE COUNTY .....
... 19
IV. LIMITED CONSIDERATION OF ALTERNATIVES
TO THE PROPOSED PROJECT .. . ...................
...... 20
A. LANDFILL OPERATIONS ... ..:.....................
20
LChemical
or Foam Cover .......................
20
2.
Tarp Intermediate Cover ............. . ..:.......
21
3.
Leachate Recirculation to Accelerate
Decomposition ...... :...... . .. . ..............
22
4.
Shredding and Biostabilization ................
. . 23
5.
Baling ......,. ..............................
23
6.
Landfill Reclamation (Mining) .....................
24
7.
Incineration ............................_....,.
25
B. SOURCE REDUCTION ........ .. 25
1. County Policy Options .. 26
2. County Tax on Commercial Generators ............. 26
3. County Outreach Program to Promote Source
Reduction ............................... ..... 26
4. County Enforced Reporting and Enforcement ..:....:. 26
5, County Programs for Market Development
And Purchasing ... .......................,... , .. , 26
APPENDIX A DIVERSION ALTERNATIVES ... A-1
The Need for the Project
Issue. Some commentators expressed concern about the need for the landfill
expansion. Specifically, some commentators stated that there is no landfill crisis and that
there will be a "glut" of landfills in the next 1 to 4 years. Additionally, some commentators
stated that the Chiquita Canyon Landfill is not needed because the landfill is not currently
operating at full capacity and because the market for recyclables is booming. Finally, one
commentator was concerned that the proposed recycling facilities were not a guaranteed part
of the plan and that Laidlaw has no incentive to construct them..
Response. The County Is Facing a Severe Landfill Crisis. The County's experts in
waste disposal have testified that the County faces a severe landfill crisis. At the August 9,
1995 hearing on this Project, Jack R. Michaels, Special Assistant for the Waste Management
Programs for the County's Department of Public Works, described the serious scope of that
crisis in clear and compelling terms. See August 9, 1995, Hearing Transcript, pp. 53-78.
Mr. Michaels explained that the total permitted capacity is too low to meet the
County's legal requirements. Mr. Michaels explained that A.B. 939 requires every county to
prepare a plan providing for at least 15 years of disposal capacity within the county. Mr.
Michaels testified that Los Angeles County has less than 3 years capacity. By no stretch of
logic can this situation be described as anything less than a crisis.
Contributing to the severity of this crisis is the fact that it generally takes
between 3 to 10 years to get additional landfill capacity permitted. Mr. Michaels pointed to
Sunshine Canyon Landfill as a typical example. Proponents of the Sunshine Canyon Landfill
expansion filed an expansion application in 1984 and yet additional disposal capacity will not
be available until 1996 at the earliest. In light of this substantial time lag between submitting
a project application and actually getting approval, the County's mere 3 years worth of
capacity represents an urgent problem.
Additionally, Mr. Michaels testified that even if every currently proposed
landfill expansion in Los Angeles County were approved, the legal mandate of A.B. 939 is
still unlikely to be met. See August 9, 1995, Hearing Transcript, pp. 66-67.
Chiquita Carryon Is Needed To Help Solve The County's Crisis. The Chiquita
Canyon Landfill is currently operating at an average of 1,720 tons per day, although it has in
the past operated at and near its maximum permitted daily capacity of 5,000 tpd. Far from
meaning that Chiquita Canyon is not needed, however, this fact simply demonstrates that
waste disposal practices vary from time to time based on many factors, including the distance
waste needs to travel, the presence of other sources of landfill capacity, whether certain
landfills must pay taxes that other landfills need not pay, and so on. As factors change, any
particular landfill's usage might increase or decrease. However, the overriding fact remains
that taking all County landfills combined there are currently far less than 15 years of
permitted disposal capacity in Los Angeles County. The Chiquita Canyon Landfill will be a
major factor in helping to relieve some of the severity of this crisis.
El
As discussed above, the County is required by state law to identify in its
Integrated Solid Waste Management Plan, 15 years of permitted disposal capacity. So, even
assuming that A.B. 939's source reduction and recycling goals are fully met, there is a
tremendous need for additional disposal capacity. Laidlaw's request for approximately 29
million tons of additional capacity is designed to provide the necessary flexibility so that the
County can obtain the maximum benefit from the landfill's disposal capacity in the future.
Of course, in the future as in the past, Chiquita Canyon's waste intake will vary from time to
time. Still, the County's severe crisis makes it very important that Chiquita Canyon have the
flexibility to respond to waste disposal demands as needed.
Recycling Is Only One Part Of The Solution. Recycling and waste reduction is
a key part of the solution to the County's solid waste disposal crisis — but it is not the whole
answer. Some commentators have forgotten that even with full implementation of A.B.
939's ambitious source reduction and recycling goals, the existing landfill capacity in Los
Angeles County is far below legal requirements and, unless more capacity is permitted, the
County will face a capacity shortage of crisis proportions. So, while recycling is critical to
solving the problem, it alone simply is not enough.
To set the record straight, some Project opponents mischaracterized Waste
Management's proposal at Bradley West. They claimed that instead of expanding the
Bradley West Landfill, Waste Management intends to close it and keep operating a
"recycling park". However, according to an August 15, 1995 article in The Los Angeles
Times explaining the project, Waste Management intends to close the landfill only when its
capacity is complete. Once filled, Waste Management intends to continue operating the
recycling park but would thereafter ship non -recyclable trash on rail lines to a new landfill
which is proposed, but not yet permitted, in Amboy, California. So, the reason waste is
proposed to be shipped out by rail is not because the recycling park will have eliminated the
need for the Bradley West Landfill, but rather because the landfill will be full, with no
additional expansion area available. Laidlaw is proposing recycling facilities at Chiquita
Canyon like those Waste Management is proposing at Bradley West.
Finally, with respect to the construction of recycling facilities, Project
opponents argue that there is little need for more landfill space because of the booming
market for recyclables discussed in articles like the August 15, 1995 Los Angeles Times
article and an article titled "Turning Trash Into Cash," in the July 17, 1995 issue of U.S.
News and World Report. If market demand continues as predicted, then the recycling
facilities Laidlaw proposes will be built and will be economically viable. However, as
discussed above, even with a booming market demand for recyclables and full
implementation of A.B. 939's ambitious source reduction and recycling goals, the County's
permitted landfill capacity is so low that there will still be a desperate need for additional
landfill disposal capacity.
5
Potential Waste Disposal and Reduction Alternatives
Issue. Some commentators have suggested additional alternatives to the expansion of
Chiquita Canyon Landfill. Specifically, commentators urged consideration of the following
alternatives: increased waste diversion and recycling, outlawing landfills and creating a solid
waste disposal system similar to Germany's, building a waste -to -energy incineration facility
similar to one supposedly operating in Phoenix, earthworm farms, rail haul, and gasification.
Additionally, several commentators expressed concern that sending waste to a landfill is the
most expensive method of dealing with solid waste.
Response. Laidlaw encourages all efforts that can help reduce waste that must go into
landfills, and this Project is designed to help with that goal by providing for a materials
recovery facility, a recyclable household hazardous waste facility, and a composting facility.
It is important to keep in mind, however, that the commentators' suggestions do not present
alternatives in the sense that any of them could completely offset the need for a landfill.
Rather, these potential alternatives are technologies that can be employed for the purpose of
reducing the amount of waste that will eventually need to go into a landfill. With this
important distinction in mind, we discuss below each of the alternatives recommended by the
commentators. Our point is not to discourage or belittle waste reduction efforts -- in fact
Laidlaw's Project incorporates and encourages those goals -- but we consider it important
that the Commission understand the reality of these potential alternatives rather than just
hearing the overstated hopes of their enthusiasts.
Increased Waste Diversion and Reacling. Waste diversion is an umbrella
term for several technologies including recycling, resource recovery, and composting, among
others. The Los Angeles County Department of Public Works has estimated that 22.2
percent of the waste stream was diverted from landfills in 1993 through these processes.
This percentage is required to increase to 25 percent in 1995, and then to 50 percent in 2000,
under the mandates of A.B. 939.
The 50 percent waste diversion goal has been characterized by the County
Sanitation Districts as aggressive and optimistic and by the Los Angeles Department of
Public Works as "difficult at best." Factors cited as making this goal difficult include data
indicating that only 77 percent of the total waste stream is eligible for waste diversion due to
contamination of recyclable materials, as well as a dearth of specific facilities to handle,
process and store these materials. A 1991 review of the most effective municipal recycling
and composting programs in the country found that the highest recycling/composting
percentage documented in a major metropolitan area was 36 percent.
Laidlaw's project will help the County meet its waste diversion and recycling
goals. The proposed Project includes a materials recovery facility, a recyclable household
hazardous waste facility, and a composting operation. The application of each of these
technologies to the Project is discussed extensively in the Draft EIR on pages II -56 through
II -69. Importantly, the City of Santa Clarita's plan to comply with A.B. 939's waste
diversion goals identifies a materials recovery facility at Chiquita Canyon as a component of
its effort to meet the law's requirements.
11
The German System. Several commentators were under the impression that
Germany outlawed landfills several years ago in favor of better waste technologies with
lower costs. In fact, the commentators are mistaken. There are existing landfills in
Germany which are currently operational. Many of these landfills will reach their capacity
within the next five years. Because Germany is so densely populated, there is a limited
amount of space available for new landfill developments. These space constraints have been
partly responsible for the development by the German government of a new regulatory
framework for waste disposal which sets the following priority for the various methods of
waste disposal: (1) recycling; (2) conversion of waste into inert waste through incineration
or other methods; and (3)landfilling.
With this new focus on recycling, the German legislature passed a series of the
most aggressive recycling laws in the world. Under the new laws, retailers are legally
obligated to take back the packaging left over from any product they sell and arrange for its
recycling. To accomplish this, retailers and manufactures have set up a private system of
waste collection for the recycling of packaging items called the "Dual System" and run by
Duales System Deutschland (DSD). While initially considered one of the best solutions to
Germany's solid waste crisis, this program has severe problems of its own. Critics of the
system point out that it has led to higher prices for nearly all consumer goods, and the DSD
faces an enormous deficit which, according to some sources, is approximately $686 million
over the past five years.
Because of its much higher costs, such a drastic re -direction of the American
waste disposal system would require a national commitment to divert scarce public funds
from other priorities (like law enforcement and health care) to solid waste disposal. It would
also require making difficult trade-offs with air quality goals to increase the use of waste
incineration. As such, implementing a "German system" is far beyond the scope of Los
Angeles County's jurisdiction and does not represent a realistic method of eliminating the
role of landfills as a continuing part of the County's waste disposal system.
Waste-to-Engay Facility in Phoenix. Several commentators were under the
impression that there is a waste -to -energy facility in Phoenix which should have been
considered as an alternative to expanding the landfill. To avoid confusion, it is important to
keep in mind that waste -to -energy facilities are actually incinerators that bum waste and then
capture some of the heat produced to make steam, hot water, or power. As such, the high
costs, severe regulatory burdens, and air quality concerns associated with incinerators are
also problems faced by waste -to -energy facilities. These waste -to -energy hurdles are
especially problematic in the Los Angeles area, where we face the worst air pollution
problem in the country and, thus, the strictest air pollution regulations. Further, the ash
from waste -to -energy facilities must be tested to determine whether it is a hazardous
material, and if so the ash must be shipped under strict regulations to expensive hazardous
waste disposal facilities.
According to recent conversations with the Arizona Department of
Environmental Quality (the agency in charge of regulating solid waste management in
Arizona), there is no municipal solid waste incinerator permitted for operation anywhere in
the State of Arizona. There are some small incinerators in Arizona used only for burning
7
petroleum -contaminated soils, medical wastes, tires and used oils, but practically all of the
state's municipal solid waste is disposed of in landfills.
Although Phoenix does not have a waste -to -energy plant, there are
approximately 125 waste -to -energy facilities operating nationwide. An October 11, 1994
article in The New York Times detailed a recent trend whereby many municipalities with
plans to build waste -to -energy plants are canceling those plans, and some cities with waste -
to -energy plants are considering closing them down in favor of disposing of waste in
landfills. According to the article, several recent developments have made waste -to -energy
facilities unattractive to these communities. First, the United States Environmental
Protection Agency has passed stricter air quality standards which have increased the cost of
incineration. Additionally, a recent Supreme Court decision held that incineration ash should
be tested as potentially hazardous, and, if found to be so, it must be disposed of in expensive
hazardous waste facilities. And finally, exacerbating the problem is the fact that energy
prices have dropped, making the energy generated by the plants less valuable. The result of
these pressures has been that 77 communities have canceled plans to build new waste -to -
energy plants since 1991.
Eanhworm Farms. The controlled use of worms to digest organic materials is
commonly referred to as vermicomposting. Worms are capable of digesting a variety of
organic materials, including food waste, yard waste, paper, sewage sludge, and manures.
Certain species of earthworms, especially Eisenia foetida and Lumbricus rubellus, are
particularly efficient in breaking down these organic materials very rapidly and fragmenting
them into much finer particles. The products of digestion that are excreted by the worms are
known as castings. The worm castings make an excellent soil amendment that compares
favorably with a high-quality compost. In addition, the worms reproduce at a fast rate and
can be another product of the process.
Vermicomposting has been successful only on a very small scale. This is
because successful vermicomposting requires that the worms be maintained in an
environment suited to their physiological needs. If conditions are unsuitable, the worms will
either die or migrate to more suitable environs. The worms are also very sensitive to
ammonia, salts, and other chemicals. Based on the information available in the technical
literature, the largest vermicomposting operations have a throughput capacity of only about
100 tons per day. Moreover, there are very few even this large.
Another problem with vermicomposting is that it takes up a lot of space -- far
more than traditional composting. This is because vermicomposting beds must either be kept
very shallow with only a few inches of new material added each day to prevent heat
build-up, or the organic material must first be composted using conventional composting
techniques before being fed to the worms. This results in vermicomposting being a much
more area -intensive process than conventional composting. Another drawback of
vermicomposting is that, to avoid problems with weed seeds and pathogens, the material may
need to be precomposted or sterilized.
While vermicomposting is a potentially promising waste handling option for
certain types of wastes, there remain a number of challenges to overcome before it is
91
commercially viable beyond a very small scale. And, of course, vermicomposting can only
be used for organic wastes so it could never eliminate the need for landfills.
Rail Haul. As urban landfills reach capacity, there will be the need to utilize
landfill space at more remote locations. It is important to keep in mind that this will not be
an alternative to landfill disposal, rather it will be making use of landfills elsewhere. Also,
because of the substantial transportation costs, these options are a high-cost alternative to
local landfill disposal, so they are not seen as a substitute for existing local landfill options.
In response to the need to provide both additional landfill capacity and an
economical transportation method, rail haul landfill sites have been developed or proposed.
The Los Angeles County Department of Public Works and County Sanitation Districts of Los
Angeles County are considering several rail haul sites in their long-range solid waste
management planning, including the East Carbon Sanitary Landfill (which was recently
purchased by Laidlaw's sister company, Laidlaw Environmental Services), La Paz Landfill,
Franconia Landfill, Mesquite Regional Landfill, Eagle Mountain Landfill, and Bolo Station
Landfill. One or more of these sites could help make up for in -county landfill capacity as
the County's disposal capacity is depleted.
Of the rail haul sites being considered, the East Carbon Sanitary Landfill,
located in Carbon County, Utah, and the La Paz Landfill, located in La Paz County,
Arizona, are permitted, operating landfills. The Franconia Landfill, located in Mohave
County, Arizona, is permitted but not yet constructed. The others are at various stages of
permitting. The Bolo Station Landfill, which was specifically mentioned by one
commentator, has had a final environmental impact report prepared that is being considered
by the San Bernardino County Board of Supervisors. Like most proposed landfills, there is
organized opposition to the Bolo Station Landfill. It is unknown if and when the Bolo
Station Landfill and the other unpermitted rail haul sites will receive all necessary permits
and approvals, and begin operations.
The Draft EIR for this Project identified and evaluated Project alternatives,
including rail haul. See Draft EIR, pp. VII -34 to VII -41. While ultimately rail haul may
play a role in the solid waste management system for Los Angeles County, the Draft EIR
concluded that rail haul would not meet a basic Project objective of securing landfill capacity
in close proximity to population centers prior to expected capacity shortfalls. Additionally,
the rail haul option is a high-cost alternative to local disposal, so it will require a greater
share of scarce public funds than local landfill disposal.
Gasi; cation. Several commentators mentioned the gasification technology
currently under development by Southern California Edison. Our understanding is that this
experimental technology is based on a fluidized bed combustor. A fluidized bed combustor
typically burns processed municipal solid waste in a heated bed of non-combustible material,
such as sand. While details of this experimental technology are not available, it is important
to keep in mind that the only combustion technologies that have been developed on a
commercial scale in the United States are mass bum incinerators, refuse -derived fuel
incinerators, and rotary combustors. Other technologies, such as pyrolysis and fluidized bed
combustion, have never advanced beyond a bench or pilot scale facility. In any event, it
N
would be irresponsible to respond to an immediate waste disposal crisis simply by wishing
for some new experimental technology to arrive overnight. Clearly, while every reasonable
alternative should be pursued, the County has to behave responsibly based on technology
available today.
Comparison of Costs of Alternatives. Some commentators contended that
sending waste to a landfill is the most expensive solid waste disposal option. Although it is
difficult to calculate costs, studies have demonstrated that a landfill is actually the least
expensive method of disposing of solid waste. According to a 1994 report, "The Role of
Recycling in Integrated Solid Waste Management to the Year 2000," by Franklin Associates,
Ltd. for Keep America Beautiful, localities nationwide spend on average only $87 per ton to
bury waste in a landfill, compared to $100-104 per ton for curbside recycling, $102 for
composting, and $134 for incineration. Further, with the use of landfills, the community
eventually gets to reuse the site for other beneficial uses, such as golf courses or other
desirable public uses.
10
Project Impacts on Water Quality
Issue. Some commentators expressed concern about potential water quality impacts
from the Project. Some specific concerns involved the potential for groundwater impacts
from current operations and from the proposed landfill expansion, as well as potential
impacts on the Santa Clara River from potential siltation.
Response. Water quality issues have been thoroughly analyzed and are addressed in
detail in the Draft EIR in Sections IV.E and N.F. As staled in the Draft EIR, there will not
be any unmitigated water quality impacts from the Project.
Some of the commentators are concerned about current groundwater quality
impacts. It is important to recognize that the only current groundwater impacts at the landfill
are from landfill gas -related volatile organic compounds originating from portions of the
landfill that do not have a composite liner. The Primary Canyon landfill area, which is
unlined, commenced operation in approximately 1970, long before Laidlaw acquired the
landfill in 1986. Even though the groundwater impacts associated with the Primary Canyon
landfill area were not caused by Laidlaw, Laidlaw has moved aggressively to correct the
problem. The impacts are being remedied through Laidlaw's corrective action plan under the
supervision of the Los Angeles Regional Water Quality Control Board (RWQCB). Laidlaw's
efforts have nearly eliminated those impacts, and Laidlaw is committed to continuing its
successful efforts in this regard.
Recently, volatile organic compounds were detected in a groundwater
monitoring well, located upgradient from the Canyon B landfill area. Because the Canyon B
liner was installed in 1988, it was installed at a time when regulatory agencies were not fully
knowledgeable of the benefits associated with geosynthetic liners. Thus, the Canyon B
landfill area was constructed without a composite liner at the direction of the RWQCB.
Laidlaw itself had proposed utilizing a geomembrane liner in the Canyon B landfill area, but
regulatory agency staff required that Laidlaw install a clay liner which does not have as good
containment characteristics as a geomembrane liner. Because the volatile organic compounds
were detected in an upgradient (the opposite direction of groundwater flow) monitoring well
and are similar to the compounds detected near the Primary Canyon landfill area, landfill
gas, not a landfill leak, is the likely impact source. Laidlaw is working with the RWQCB
and has already taken steps to confirm landfill gas as the source of the impact.
It is important to note that the impacts in the Primary Canyon (DW -1) and
Canyon B (DW -3) are related issues. So much effort has been invested into addressing the
landfill gas migration in the Primary Canyon that vacuum pull was not available in the
farthest reaches of Canyon B. As a result, in September 1995, applications were filed with
the SCAQMD to expand both the flare facility and the landfill gas collection system. The
additional vacuum will provide sufficient capacity to address both areas. Upon completion of
the Project's permitting process, an additional landfill gas collection expansion will be
permitted to address the requirements of the expanded landfill.
As stated in the Draft EIR Project description, all future landfill areas will F
have a composite liner. A composite liner has very good waste containment characteristics
11
and will control landfill gas migration and minimise the potential for their impacts on
groundwater. Additionally, the existing groundwater quality monitoring system will be
expanded to cover the expanded landfill. Importantly, the California Department of Health
Services' Drinking Water Field Operations Branch stated that "the mitigation and monitoring
procedures that Laidlaw is proposing will limit any potential contamination and provide for
early detection of groundwater contamination and plum[e] migration." Similarly, the
RWQCB reviewed the Draft EIR for potential impacts to groundwater and found that the
proposed Project is protective of groundwater..
With respect to the concern about silt entering the Santa Clara Ri.er, a
comprehensive erosion control plan has been prepared for the site. This plan is part of the
detailed Project description, prepared by Laidlaw's landfill engineering consultant, and has
been submitted to the Los Angeles County Department of Regional Planning as part of the
background information for the Draft EIR. The erosion control plan presents several
measures, including construction of on-site sedimentation basins, to control erosion and
prevent silt from entering the Santa Clara River. Although the erosion control plan addresses
the landfill expansion, Laidlaw is already working with the RWQCB to begin implementing
additional erosion control measures for the existing site before the landfill expansion is
approved.
Additionally, Laidlaw is operating the existing landfill under the conditions of
a National Pollutant Discharge Elimination System general permit administered by the State
Water Resources Control Board. The permit conditions require preparing a stormwater
pollution prevention plan and a stormwater monitoring plan, both of which have been
prepared. The stormwater pollution prevention plan describes the best management practices
to be implemented to control and prevent pollutants, including silt, from leaving the site.
The stormwater monitoring plan requires sampling stormwater flows before they leave the
site. Currently, samples are taken on-site upstream of the Santa Clara River and Castaic
Creek. Analytical results are reported to the RWQCB.
12
Project Impacts on Air Quality
Issue. Several commentators raised concerns about the proposed Project's impact on
air quality. These included general concerns, as well as specific concerns about particulate
matter (dust) impacts in Val Verde, health-related impacts, and the proposed measures to be
implemented by Laidlaw to mitigate air quality impacts.
Response. Air quality is a subject of concern to everyone living in the Los Angeles
air basin. The existing air quality does not meet state and federal standards with regard to
some criteria pollutants. Laidlaw, as a responsible neighbor, shares this concern.
Accordingly, Laidlaw had a comprehensive evaluation of the Project's potential air quality
impacts performed to aid in the preparation of the Draft EIR. That evaluation is much more
comprehensive than air quality impact evaluations performed for other recently proposed and
approved landfill projects. The evaluation is discussed in Section IV.G of the Draft EIR and
is presented in Appendix G.
Because of the importance of this issue, Laidlaw's scientific experts have
prepared another more refined air quality analysis using more realistic site-specific
assumptions than those required to be used in an EIR. That study has just been completed,
and copies of it are being provided to the Commission under separate cover. Laidlaw is
proud of that study because it makes clear that the proposed Project will not cause any
significant health risks.
Criteria Pollutant Impacts. The air quality evaluation performed to aid in
preparing the Draft EIR was performed in accordance with the South Coast Air Quality
Management District's (SCAQMD) California Environmental Quality Act (CEQA)
guidelines. The SCAQMD CEQA guidelines are geared toward projects, such as a factory
or a shopping center, and approach projects in two phases, the construction phase and the
operations phaseY Higher air quality impacts are allowed for the construction phase than
the operations phase because the construction phase is considered to be short term.
However, because there are construction activities occurring throughout a landfill's
operation, Laidlaw elected to combine the air quality emissions for the construction phase
and operations phase rather than evaluate them separately, thus providing for a more
conservative, overstated estimate of impacts during the operations phase.
Even though the SCAQMD's methodology is a very conservative one and
Laidlaw elected to combine the construction phase and operations phase emissions, the air
quality evaluation used to aid the preparation of the Draft EIR determined that the Project
1. It should be noted that SCAQMD's CEQA guidelines are intended to evaluate air
quality impacts associated with new air emissions. A solid waste facility, in general, and a
landfill, in particular, do not necessarily create new air emissions because the activity at one
facility is replacing an activity at another facility. Therefore, within an air basin, air quality
impacts related to a new or expanded solid waste facility are not necessarily new impacts but
rather existing impacts that have been occurring somewhere else within the air basin.
13
only exceeded air quality standards for two pollutants: particulate matter and nitrogen
dioxide.
Because of its concern about potential air quality impacts, however, Laidlaw
has further evaluated potential air quality impacts using assumptions and methodologies that
are more realistic than those required by the SCAQMD for an EIR. These assumptions are
fully supported on a technical basis by reputable scientific literature. The results show that
the Project's annual nitrogen dioxide impact will not exceed the air quality standard.
Further, while the proposed Project's PM -10 emissions will exceed air quality standards at
the property boundary, they will decrease very quickly with distance from the site and are
not expected to exceed the national air quality standard even as close as Val VerdeY
Accordingly, the proposed Project will not pose any significant health risks to any,
community.
Also important is the fact that, because the proposed Project makes several site
improvements feasible (such as road paving), the PM -10 concentrations for the proposed
Project are actually less than the impacts from the existing facility.
Health Concerns. With respect to health-related impacts, the air quality
evaluation presented in Appendix G of the Draft EIR assessed health risks associated with
toxic gases that might be emitted from the Project. The health risk assessment considered
both cancer and noncancer risks. The health risk assessment addressed a total of 19
substances based on lists for the proposed SCAQMD Rule 1401 and Assembly Bill 2588 (the
Air Toxics Hot Spots Information and Assessment Act). Of the 19 substances, 9 are
considered carcinogenic and are evaluated as part of the cancer risk evaluation. The
noncancer risk evaluation addressed all 19 substances for chronic impacts, and 5 of the 19
for acute impacts. The lifetime carcinogenic risk was estimated using the following worst-
case assumptions: a hypothetical individual was assumed to reside continuously for 70 years
at the off-site maximum ground -level location. Chronic and acute noncarcinogenic health
effects were also estimated for this hypothetical "maximally exposed" individual. The health
risk assessment also utilizes extremely conservative assumptions regarding the duration of
exposure and potency. As a result, the estimated health risk can be confidently considered to
be the "upper level of risk." The actual risk is very likely to be much lower.
Despite its extremely conservative assumptions, the evaluation concluded that
the Project will not cause significant risk or exposure impacts, and in fact are below the
standards specified by the SCAQMD..
Mitigation Measures. The SCAQMD CEQA guidelines require that a project
proponent implement all feasible mitigation measures if significant air quality impacts are
2. The state air quality standard for annual PM -10 concentrations is more stringent than
the national standard. Because the background PM -10 concentrations already exceed the
state standard, however, the SCAQMD allows projects an incremental increase over
background concentrations. In general, the PM -10 concentrations in Val Verde will not
exceed the allowable annual incremental increase.
14
predicted. The Draft EIR in Section IV.G describes the various mitigation measures to be
implemented by Laidlaw. These mitigation measures, including suspending construction
activities during Stage 2 and Stage 3 smog alerts, substantially reduce the Project's air
quality impacts and Laidlaw is committed to implementing them. As noted above, the
proposed Project's PM -10 emissions are actually less than the existing facility's emissions
because of mitigation measures to be implemented as part of the Project.
In addition to the specific measures to mitigate air quality impacts, several of
the Project elements will also serve to mitigate air quality impacts assoc;ated with the
landfill. Both the proposed materials recovery facility and composting facility will divert
materials from the landfill. As a result, potential air quality impacts that may have occurred
if the diverted materials had been landfilled will be reduced.
15
Effects of Landfill Gas Emissions: Toxicity and Odors
Issue. Several individuals commented on two specific areas associated with potential
landfill gas emissions: toxic gases and odors.
Response. The issue of health risk associated with the potential for toxic gases
being released from the landfill was addressed in detail in Volume II of the Draft EIR's
technical appendices. Additionally, the results are summarized in the Draft EIR on pages
IV.G-33 through IV.G-35. In summary, the results showed that the potential excess cancer
risk associated with the fully -developed Project did not exceed the standards defined by the
South Coast Air Quality Management District (SCAQMD) and the California Air Pollution
Control Officers' Association (CAPCOA). As a result, any impacts would be insignificant.
With respect to odor complaints, it is important to note the history of odor
complaints associated with the operation of the landfill. The facts are that there has never
been an odor complaint that has been confirmed by the SCAQMD. In fact, the SCAQMD
reports that it did not receive any odor complaints until recently when certain Project
opponents began actively seeking to block the proposed Project. Since then, the SCAQMD
has investigated many odor complaints it has received but has never found there to be gLny
odor problem from the landfill. Despite many unannounced inspections, Laidlaw has never
been cited for any odor problems. Indeed, the Commission itself toured the site with its staff
and we understand no odor was detected.
In recognition of all of this information, and in an effort to put this issue to
rest, Laidlaw commissioned Parsons Engineering Science, Inc., a highly -respected
engineering firm, to conduct odor sampling in and around the landfill, and to analyze those
samples to determine if the landfill might be a possible source of odors. Rather than leave
anything to chance, Laidlaw worked with the SCAQMD to determine when and where to
conduct the testing in order to increase the odds of detecting odors. Despite this, Parsons'
testing and analysis detected no odors at all at the landfill. For the Commission's reference,
copies of the: Parsons report are being provided under separate cover.
Conclusion. In light of the fact that odor complaints first started only after the
Project became a topic of local political debate, that the SCAQMD has never confirmed any
such complaint, that the Commission itself detected no odors, that Laidlaw's employees
detect no odors, and that an expert scientific analysis detected no odors, it is highly unlikely
that the Chiquita Canyon Landfill causes any odor problem at all.
16
Operation and Reliability of the Landfill's Gas Extraction System
Issue. Several commentators stated that a landfill gas collection system cannot
operate at 100% efficiency because of the potential to create fires in the landfill and,
therefore, there is a potential problem associated with "explosive gas control." Additionally,
one commentator expressed concern about the possibility that the landfill's gas extraction
system would stop working while the landfill was still operating or would stop functioning
after the landfill closed.
Response. The purpose of the landfill gas collection and disposal system is to control
the emissions of landfill gas such that a potentially unhealthy or hazardous condition is not
created. As shown in the Draft EIR, a health risk analysis was prepared specifically looking
at the potential for excess cancer risk associated with the proposed Project. It concluded that
the potential risk for excess cancer associated with the Project was less than the South Coast
Air Quality Management District standard.
A hazardous condition can be created if sufficient landfill gas is allowed to
migrate to a nearby structure where it can build up in a confined space. By installing a
landfill gas extraction system, this is generally avoided. Extraction of the landfill gas
reduces the pressure within the landfill which minimizes the potential to migrate to on-site or
off-site structures. As an additional precaution, each on-site structure has a combustible gas
monitor to identify any conditions where landfill gas buildup might be a problem. Although
this alarm is frequently tested, it has never gone off except while being tested.
Through a vacuum placed on the landfill by the extraction system, landfill gas
is removed. It is possible, however, for the system to create too much of a vacuum thereby
pulling oxygen into the landfill from above the surface. With the heat associated with the
decomposition of refuse in the landfill, the addition of oxygen can create the potential for
fires that could burn refuse within the landfill. To avoid this, Laidlaw employs a full-time
landfill gas technician. The technician's role is to monitor the vacuum at each of the gas
wells. By frequently inspecting and testing the wells, he can tell if oxygen is being pulled
into the landfill by the vacuum on a well. If so, this can easily be corrected by adjusting the
valve at the well to reduce the vacuum.
The bottom line is that there is an appropriate range of operation which
Laidlaw operates within. By doing so, Laidlaw does not allow too much landfill gas to
escape the landfill, which eliminates the potential for unhealthy or hazardous conditions, and
it also does not extract too much landfill gas, which eliminates the potential for fires. To
confirm that Laidlaw is operating within that range, there is a SCAQMD Rule 1150.1
monitoring program at the landfill, the results of which are reported to the SCAQMD on a
quarterly basis.
Regarding the period after closure, Laidlaw is required to demonstrate both the
economic and technological capability to monitor and maintain the landfill and its
environmental systems for a minimum of 30 years after the last receipt of waste at the
landfill. Typically, decomposing refuse only generates landfill gas for about 20 years. Also,
17
Laidlaw will not be allowed to cease monitoring and maintenance until it is demonstrated that
landfill gas poses no hazard to the environment.
IU
Project Impacts on Traffic
Issue. Several commentators raised concerns about the potential impact the landfill
expansion will have on area traffic. Specifically, commentators stated that the section of
Route 126 between the Interstate 5 and the Ventura County Line is one of the most
dangerous in the County. Additionally, commentators were concerned with the impact that
additional waste disposal trucks would have on the Route 126 corridor and with the impact
that road construction will have on traffic due to the landfill expansion. Commentators also
stated that these impacts were not addressed by the Draft EIR and that the Draft EIR left
Post Office traffic out of its analysis. Finally, commentators expressed concern over the
location of the landfill entrance and exit. Specifically, commentators stated that the entrance
and exit were located at a blind comer and a suggestion was made to consider Wolcott Way
as a potential entrance.
Response. The Current Situation On State Route 126. Accident potential along the
highway is addressed in the Draft EIR on pages IV.A-26 through IV.A-27. The traffic
accident data indicates that the accident rate along this section has decreased in recent years.
In the most recent 5 -year period analyzed, only one accident was a fatal accident, compared
to 6 fatalities in a prior 3 -year analysis period. No evidence exists to suggest that landfill
traffic was involved.
Planned Improvements To State Route 126. Caltrans plans to widen State
Route 126 from two lanes to four lanes in the near future, which will further improve the
safety of the roadway by providing two travel lanes and left -turn lanes in each direction, and
by smoothing some of the curves in the roadway. Construction is scheduled to begin in
December 1996, and to he completed in December 1998. The actual amount of time that
construction will be taking place near the landfill entrance has not been identified. Laidlaw
has committed to providing advance warning signs on the highway. The Project has been
conditioned to coordinate with Caltrans on the design of the roadway at the Project entrance,
to ensure incorporation of additional turning lane facilities and signing. A traffic signal at
the Project is to be installed at the time the landfill receives the amount of refuse that would
warrant a traffic signal. Additionally, the Draft EIR contains mitigation measures such as a
second truck scale, warning signs, and a traffic signal which are intended to increase
operating safety at the landfill entrance.
The Proiect Will Have No Si2niticant Traffic Impact. The Draft EIR
demonstrates that the Project will not have a significant impact on the roadway operating
level of service, with or without the widening of State Route 126. This conclusion is
supported by the Draft EIR's extensive analysis of the operation of Route 126 east and west
of the Project site under a multitude of scenarios. The Draft EIR showed that the Project's
contribution to traffic represents only a nominal portion of the existing and the projected
daily traffic volumes on Route 126.
Post office Traffic Was Accounted For. The traffic study included both
existing traffic and future traffic volumes on Route 126, and at the Route 126/Wolcott Way
intersection (which is the entrance to the Post Office facility). Post Office traffic was
19
included in that analysis. Project truck traffic was identified by truck type, and was
accounted for in the traffic study by applying a factor of 2.0 to all trucks.
Wolcott Way Could Not Work As a Landfill Entrance. The entrance to the
landfill is located on the outside of a horizontal curve, and at the crest of a vertical curve,
with a sight distance of over 750 feet looking to the east, and over 1,000 feet looking to the
west. These distances are considered adequate in relation to county and state standards.
With the widening of Route 126, the horizontal curve will be smoothed, and the sight
distance will be further improved. Wolcott Way was not evaluated as a potential new
entrance to the landfill. The terrain between Wolcott Way and the active landfill is very
steep, with a 200 -foot ridge separating the two. The entrance road would be too steep to
allow safe access to the facility. Therefore, providing a truck entrance through this terrain is
not practicable, would not be safe, and could increase visibility of operations along Route
126.
20
Project Impacts on Val Verde Property Values
Issue. Some commentators expressed concern that the proposed landfill expansion
would reduce residential property values in Val Verde.
Response. Recognizing the importance of this issue to homeowners in Val Verde,
Laidlaw commissioned Robert Charles Lesser & Co, ("RCL"), a leading real estate advisory
firm, to compile extensive data and to conduct a thorough analysis of that data to determine
whether the Chiquita Canyon Landfill has had or would be expected to have any negative
it-lpact on Val Verde property values. After an exhaustive analysis, RCL concluded that the
Chiquita Canyon Landfill has not affected property values at all. Moreover, this conclusion
is strongly supported by RCL's extensive review of property valuation studies from across
the country, the overwhelming majority of which show that being near an operating landfill
does not adversely affect property values.
RCL's analysis involved several steps. First, RCL compiled data on housing
characteristics in order to develop housing trends in Val Verde, including obtaining data
relating to lot size, unit size, sale price, assessor's value, year built, sales and price per
square foot. Second, RCL compared confirmed home sales between 1990 and 1994 in Val
Verde to those in the Santa Clarita Valley. RCL also compiled socioeconomic and housing
data on Los Angeles County to provide a framework. Third, RCL conducted a literature
search to review conclusions addressing various landfills and their impacts, or lack thereof,
on property values.
Based on RCL's analysis of this extensive data, RCL reached the following
conclusions:
• Val Verde has experienced tremendous growth in new housing in the period after the
landfill began operations. In fact, nearly two-thirds of Val Verde's total current
housing stock was built after the landfill commenced operations in approximately
1970. Moreover, about one-fourth of the homes in Val Verde were built after 1989,
the year Laidlaw announced its plans to expand the landfill. This shows that even
though the landfill has been operating for about 25 years, a continuing stream of
people have been willing to make long-term financial commitments to live in this
community.
• Not only were about one-fourth of the homes in Val Verde built after Laidlaw
announced its expansion plans in 1989, but one-half of those were built in the part of
Val Verde closest to the landfill.
• Even though the housing market throughout Southern California has dropped
substantially since 1990, Val Verde has fared better than the rest of the Santa Clarity
Valley. Since 1990, the regional economic recession has caused home prices in the
rest of the Santa Clarity Valley to drop by about 20%, but in Val Verde the price
drop was 17%. Clearly, being next to the Chiquita Canyon Landfill has not hurt Val
Verde's home prices.
21
After reviewing an extensive representative sampling of literature sources discussing
whether the presence of a nearby landfill might impact property values, the overriding
conclusion is that an operating landfill does not adversely affect property values in
surrounding residential areas. In virtually all cases, researchers did not find any
critical distinction between prices of homes located near a landfill and homes some
distance away.
In light of these results, it is clear that the Chiquita Canyon Landfill has not
had and will not have any negative impact on property values in Val Verde.
22
Compatibility of the Landfill with Current and Planned Nearby Land Uses
Issue. Some commentators expressed concerns that the landfill might be incompatible
with current and planned nearby land uses. One individual recommended that the
Commission place similar restrictions on this Project to those placed on the Puente Hills
Landfill which prohibit any activity within 1,700 feet (actual requirement is 1,750 feet) and
prohibit landfilling within 2,000 feet of the nearest homes.
Response. The Chiquita Canyon Landfill has been in operation continuously since
about 1970, and it fits in very well with its surrounding area. In fact, because nearly two-
thirds of Val Verde's current housing stock was built since 1970 -- after the landfill fust
opened -- it is clear that most residents of Val Verde found the landfill sufficiently
compatible with residences for them to have built or bought homes nearby. Looking ahead
to the future, the proposed landfill expansion and addition of recycling operations will
continue to be appropriate to the area and has been planned so that it will not impose undue
burdens on its neighbors.
The Draft EIR analyzes potential land use concerns in great detail at pages 11-7
through II -10 and pages III -1 through III -13. The Draft EIR is especially careful to consider
future neighboring land uses (see pp. 11I4 through III -8). Importantly, the Draft EIR
analyzes all applicable land use regulations -- i.e., the County's General Plan, the Santa
Clarita Valley Area Plan, and the Castaic. Corridor Plan — and it concludes that the proposed
Project may be found to be "consistent with existing and planned land uses and zoning
requirements" (see p. I1I-12). The Draft EIR also concludes that the proposed Project is
compatible with proposed scenic trails and the policies in the County's Riding and Hiking
Trails Plan (see p. III -12).
The requirements placed on the Puente Hills Landfill are very site specific
requirements. In general, the homes of interest lie due east of the landfill. Puente Hills
Landfill is designed to expand toward the east in the direction of the homes. At Puente
Hills, the topographic features between the existing landfill and the nearby homes are east -
west trending ridges and canyons. As one looks from the east to the west toward the
expansion area, one looks up the axis of those canyons.. Even now, excavation can be
observed and, at a time in the future, the landfill will be observable from those homes. If
activities would have been allowed closer than 1,750 feet, they would have been even more
visible.
At the Chiquita Canyon Landfill, the proposed Project design separates the
nearest landfill activity from the nearest homes by approximately 1,200 feet, looking at the
"plan view" distance (i.e., not accounting for the fact that there is a mountain between the
landfill and the nearest homes).' Most importantly, however, is the fact that there is a 500-
3. Because of the ridgeline, the ground distance separating the proposed landfill activity
from the nearest home is about 1,400 feet -- about 200 feet greater than the "plan view"
distance.
23
foot high ridgeline that runs from the northeast to the southwest which separates the
community from the landfill site and will completely block any views of the landfill activity.
Nothing will be gained by adding any distance to that 1,200 feet. To the contrary, because
of the geometry of the ridgelines and the need to provide for off-site drainage from the north
end of the site to the south end of the site, simply increasing the 1,200 -foot distance could
have a dramatic negative effect on the capacity generated by the landfill expansion.
In order to minimize the loss of landfill expansion capacity, a considerable
amount of new earthfill would need to be placed to push the landfill from 1,200 and 2,000
feet from the nearest Val Verde residence. This earthfill not currently accounted for in the
design, would be required to provide for proper drainage around the landfill. This additional
earthmoving would greatly impact air quality in the area as a result of additional earthmoving
equipment efforts (NOx, CO, SOx, etc.) and additional PM -10 generated from the moving of
the soil. The effect would be to reduce the expansion capacity by approximately 3,600,000
tons (about 12% of this critically needed capacity).
In light of this, there is nothing to be gained by moving the landfill limit
further from the nearest Val Verde residence. To the contrary, the potential impact on air
quality due to greatly increased construction activity to excavate soils and import earthfill
could be dramatic. The ridgeline which serves as a physical buffer between the project and
community will not be enhanced by an increased separation distance.
FE
Project Noise Impacts
Issue. Commentators stated that there is no empirical evidence to indicate that the
ridgeline between Val Verde and the landfill would effectively reduce operational noise
levels. They also indicated that equipment operations can be heard from some of the homes
in the area.
Response. Noise impacts are not difficult to predict. The movement of sound
follows very basic scientific principles. As with light, if you block the source you can
reduce its intensity or eliminate it altogether. That is why Caltrans builds walls next to
freeways; to reduce roadway noise in adjacent neighborhoods. Section IV.J of the Draft EIR
reports on both the existing and future noise levels expected at the landfill. Noise was
measured in the community of Val Verde and at the home closest to State Route 126 at
various times during the day in 1994 when the landfill was operating. Figure 4.J-1 in the
Draft EIR shows those locations. The Draft EIR states that noise in Val Verde is "typical of
a rural residential community, whose ambient noise is influenced by periodic vehicles,
barking dogs, farm animals and minor human activity." Observations made during those
measurements indicated that the 12 pieces of landfill equipment currently in use were not
audible. Under the proposed expansion, the landfill would only need 4 more pieces of
equipment.
As indicated on pages IV.J-9 and 10 of the Draft EIR, the site's existing
topography acts as a natural barrier to the community, and it shields the homes from the
landfill operations. Even without accounting for the unique topography, however, noise
associated with the landfill expansion would be well below the County's standard of 65
Db(A) for residential areas. Sound levels expected onsite were calculated out to the closest
residences using the equation on page IV.J-9 to account for the reductions in noise due to the
ridge blocking the homes. This equation is a scientific method for calculating noise
reductions due to barriers. The Draft EIR indicates that the ridgeline would reduce
equipment noise by at least 20 decibels beyond the reduction associated with distance.
Therefore, even though unique atmospheric conditions might allow the landfill equipment to
be heard in the distance on some few occasions, there would be absolutely no adverse effects
on the community on a regular basis.
25
Project Impacts on the Health of the Local Community
Issue. Several commentators have claimed that the landfill is responsible for
increases in insects and rodents and, generally, for poor health in the local community.
Response. The Draft EIR has addressed the nuisance and health effects of the
expansion Project under Sections IV.G and IV.H. The County Department of Health Services
(DHS) inspects the landfill on a monthly and annual basis. Part of that inspection process
evaluates the landfill's ability to control vectors, such as insects and rodents. No violation
notices related to vector control have ever been filed with the DHS against Chiquita Canyon
Landfill.
Despite the handling of solid waste, the operational procedures established at
the landfill do not promote increases in insect and rodent populations. Each day soil cover is
applied on top of the refuse to control odors, birds, vectors, flies and other insects.
Watering applied for dust control is neither applied in such large quantities nor left standing
long enough to encourage insect populations.
Furthermore, pollution levels in the Los Angeles air basin exceed state and
federal standards for ozone (photochemical smog) and dust. Recent trends in air quality in
the Los Angeles basin have indicated that despite successful efforts to control regional
pollution levels, unhealthful conditions exist. People that are more susceptible to these levels
are individuals with asthma and other respiratory conditions. The main sources of this
pollution are cars and trucks. There is no relationship between proximity to the landfill and
respiratory effects on local individuals. It is likely that wherever those people reside in the
air basin they would be exposed to air quality that could affect their condition.
26
Laidlaw's Regulatory Compliance History at Chiquita Canyon
Issue. One commentator stated that the Draft EIR does not discuss Laidlaw's
regulatory compliance history at the Chiquita Canyon Landfill, One individual was
concerned that the landfill might currently be in violation of its height limitation. Another
individual claimed that the Chiquita Canyon Landfill has proceeded under a series of negative
declarations since its inception, and that it has not complied with the California
Environmental Quality Act.
Response. Regulatory Compliance Is Carefully Reviewed in the Draft EIR. The Draft
EIR contains a detailed discussion of Laidlaw's history of regulatory compliance at the
Chiquita Canyon Landfill. That discussion points out that the landfill has regularly
undergone monthly and annual inspections by the County DHS, the CIWMB, the RWQCB,
the SCAQMD, and other regulatory agencies to ensure regulatory compliance. The Draft
EIR then concludes that over the past ten years "these inspections have received satisfactory
ratings on most regulated operations" (p. 11-2). Additionally, the Draft EIR points out that
there have been three areas where Laidlaw has faced regulatory challenges that have required
special attention to correct, and for each of these areas the Draft EIR discusses Laidlaw's
compliance history in detail. These three areas of past concem are: (1) sewage sludge
disposal (discussed at pp. 11-2 through II -3); (2) landfill gas control (discussed at pp. 11-3
through II -4); and (3) erosion control (discussed at pp. 11-4 through 11-5). Further, the Draft
EIR contains a lengthy analysis of current water quality issues, including a discussion of
Laidlaw's compliance history with respect to water quality issues (pp. IV.F-1 through
IV.F-21).
The Current Height Limit Is Not Being Violated. The Chiquita Canyon
Landfill's existing conditional use permit (issued in 1982) contains a plot plan allowing waste
disposal at the landfill's outside boundaries for Canyon B and the Primary Canyon to be
1,220 feet above mean sea level. Because conditional use permits were generally written
with less detail in the past than they are now, that conditional use permit did not address the
fact that drainage needs to be provided for from the center of the landfill. Also, in 1984 the
State Water Resources Control Board established a minimum 3% slope requirement for
landfill drainage. Taking the 1,220 foot height limits at the boundaries of Canyon B and the
Primary Canyon, this leads to the conclusion that the center of those landfill areas must be
filled to a height slightly higher than 1,220 feet so as to comply with the legally -mandated
drainage slope requirements. At Canyon B, slope drainage requirements would add 13.5 feet
in additional permissible height at the center, and at the Primary Canyon they would add
between 20 to 40 feet
Additionally, the 1982 conditional use permit did not address the question of
refuse settlement. Because of decomposition and mechanical forces on refuse in landfills,
landfill refuse settles in a generally predictable fashion, varying from 15% to 25% of the
depth of the refuse. The 1982 permit does not make it clear whether the height limitation
applies to the final post -settlement height or to the interim pre -settlement height. Given the
depth of the refuse in the respective parts of the landfill, Canyon B is expected to settle by
15 to 25 feet, and the Primary Canyon is expected to settle by 30 to 50 feet.
27
Combining these two factors means that, in order to comply with the 1,220
foot boundary height limit after accounting for the required drainage sloping and refuse
settlement, Canyon B's maximum pre -settlement height may be between 1,248.5 and 1,258.5
feet msl, and the Primary Canyon's maximum may be between 1,270 and 1,310 feet msl.
Currently, the highest; point of Canyon B is 1,235 feet msl, and the highest point of the
Primary Canyon it is 1,252 feet msl -- both of which are well below these heights.
All Applicable CEN Requirements Have Been Consistently Complied With.
The Chiquita Canyon Landfill began its operation in about 1970. At that time, the California
Environmental Quality Act did not yet exist. Since the landfill was already in operation
when CEQA became effective, no retroactive CEQA review was required.
In the early 1980s, Laidlaw's predecessor as operator of the Chiquita Canyon
Landfill proposed an expansion of the project to add acreage associated with new canyons
A,B,C, and D. At that time, a draft environmental impact report was prepared. It was then
noticed and distributed for comments. The comments were responded to, and both the
comments and responses were incorporated into the final EIR. That document was dated
October 19, 1982 and served as the basis for the issuance of conditional use permit 1809-(S).
Since that time, there have been only two other actions requiring CEQA
activity until the current proposed Project. One involved the acceptance of de -watered
industrial and municipal sewage sludge and the other involved the final closure and
postclosure plans for the Primary Canyon and Canyon B areas of the landfill. In both
instances, the lead agency was the Los Angeles County Department of Health Services
(DHS) and in both instances it proceeded in a proper fashion. Upon receipt of the proposed
projects with mitigations identified, DHS performed an initial study. In its determination,
implementation of the projects with the proposed mitigations would not havea negative
impact on the environment. Accordingly, DHS proposed a mitigated negative declaration
(MND) as the appropriate CEQA action.. As required, DHS prepared the MNDs, advertised
their preparation in a paper of local circulation, and distributed them to other responsible
agencies. Based on the lack of significant comments, it was determined there was no need
for a public hearing and the MNDs were approved. These procedures were confirmed as
adequate by Kathryn Tobias, Chief Counsel to the California Integrated Waste Management
Board, during its July 27, 1995 hearing on the issuance of the new solid waste facilities
permit.
Ra
Concerns Regarding Current Landfill Technology
Issue. Several comments were made about the mechanics of landfills. Specifically,
one commentator stated that there is no scientific data in support of current landfill
technology. Additionally, concerns about Chiquita Canyon Landfill were raised with regard
to the lack of a separate leak detection system, inadequate setbacks, and the need for
screening berms. Concerns were also raised about preprocessing the waste before
landfilling, and alternative landfill operational practices, such as shredding and baling.
Response. There has been a great deal of research about landfills and how they
perform under a variety of conditions. There are hundreds of scientific and engineering
papers that have been written dealing with landfill design. Dr. Hari Sharma, who was
responsible for the geotechnical engineering aspects of the landfill design, is the senior author
of a book dealing with the design of landfill containment systems. Additionally, there are
many technical conferences each year where experts come together to present and discuss
new information about landfills. Finally, there are hundreds of landfills around the country
that have been designed and built and which continue to perform satisfactorily.
The existing body of scientific information about landfills is constantly being
expanded and updated. For example, after the Northridge earthquake, technical staff from
Laidlaw's engineering consultant were at the Chiquita Canyon Landfill evaluating the
earthquake's effects on the landfill. Further, the Operating Industries, Inc. Landfill, located
in the Los Angeles area, is instrumented with strong ground motion recorders. This allowed
recording of the Operating, Industries, Inc. Landfill's performance during the Northridge
earthquake. The information from the Northridge earthquake has been analyzed and applied
to the Chiquita Canyon Landfill design. As a result, it was concluded the Chiquita Canyon
Landfill performed as designed during the Northridge earthquake and is capable of
withstanding the shaking associated with the maximum probable earthquake as required by
California regulations.
The Chiquita Canyon Landfill design embodies the most current design
concepts and regulatory standards as promulgated by the federal Environmental Protection
Agency and the State of California. The liner system and leachate collection and removal
system designs are based on the latest engineering technology. The overall landfill design is
compatible with the site and the surrounding area.
California's landfill liner regulations require a composite liner comprised of a
geomembrane layer and a low -permeability soil layer. The California Regional Water
Quality Control Board, Los Angeles Region, in reviewing and approving the landfill liner
design for the Chiquita Canyon Landfill, has determined that the liner design meets all
regulatory requirements and has not imposed any additional liner design requirements.
Much of California is a desert. Little, if any, leachate is generated at landfills
located in and areas, such as Chiquita Canyon. Therefore, the potential for leachate to leak
from a lined landfill and impact underlying groundwater is minimal. Currently, about 5,000
gallons per month of leachate are collected at the Chiquita Canyon Landfill. This compares
with some eastern landfills that generate 600,000 gallons per day.
29
Several of the older, existing landfill areas at the Chiquita Canyon Landfill do
not have a composite liner. However, all landfill areas constructed since 1990, and all future
landfill areas, will have a composite liner. There is no evidence that leachate has impacted
groundwater, even from the areas that do not have a composite liner. In fact, during the
installation of landfill gas collection wells in one of the areas, refuse brought up from the
base of the landfill was dry. Based on the dry conditions at the Chiquita Canyon Landfill,
there is not a demonstrated need for a leak detection system.
As previously stated, the landfill design was developed to be compatible with
the site and surrounding area. The landfill site is a canyon with surrounding ridges that rise
to a height 500 feet higher than the nearest residence. These ridges were an integral part of
the landfill design. A line -of -sight analysis was performed during the preliminary design and
the final grading plan developed so that the landfill would not be visible from the majority of
the surrounding area. The landfill cannot be seen from any of the residences in the nearby
Val Verde community. Therefore, the need for berms to screen the landfill, as suggested by
one commentator, is unnecessary.
One commentator suggested preprocessing the waste before landfilling to
remove materials that have economic value. It is important to note that much of the waste is
already preprocessed before reaching the Chiquita Canyon Landfill. Additionally, Laidlaw is
proposing to develop several resource recovery facilities as part of the Project. Much of the
waste that is received at the landfill is from communities that have recycling programs in
place. These programs include curbside collection of separated recyclable materials and yard
waste, commercial drop-off centers, and commercial and industrial activities, such as
separation and baling of corrugated cardboard. As such, much of the recyclable material is
already recovered before it is received at the landfill. Additionally, much of the waste
received at the landfill is delivered from transfer stations. Waste is also processed at the
transfer station to recover recyclable materials before it is delivered to the landfill.
To assist in the recycling of many of these pre-processed materials, Laidlaw is
proposing several resource recovery facilities. These facilities include a materials recovery
facility (MRF), a composting facility, and a recyclable household hazardous waste facility.
Each of these facilities will complement existing and future community waste diversion
activities and assist the communities in achieving the waste diversion mandates contained in
Assembly Bill 939. Therefore, as discussed above, Laidlaw is well on the way to
implementing what the commentator has suggested.
Shredding and bailing were suggested as alternatives. Both shredding and
baling are waste handling techniques utilized before waste is landfilled. As such, they are
not alternatives to landfilling. We agree with the commentator that shredding is mainly used
with MRFs. More specifically, shredders are included in MRFs that process construction
and demolition material, or yard and wood waste. The Chiquita Canyon MRF will process
separated recyclable materials and loads than have been identified as being primarily
recyclable materials. The composting facility will have a shredder to process yard waste.
Baling is a densification process that is often used to reduce transportation
costs. However, baling does not achieve a waste density that is significantly different than
30
the density achieved by the landfill equipment utilized at the Chiquita Canyon Landfill.
Although some landfills do bale waste before landfilling, there are no advantages to baling at
the Chiquita Canyon Landfill.
31
Concerns that. Chiquita Canyon is Exceeding its Permitted Flow Rate
into the Landfill Gas Flare
Issue.. One commentator stated that the SCAQMD has put Laidlaw on notice that it is
exceeding its permitted flow rate into Laidlaw's landfill gas flare.
Response. Laidlaw is and always has been in full compliance with the flow rate
condition in its SCAQMD permit. Although a question was raised recently concerning a
potentially high flow rate, that question was resolved when it, was discovered that the flare
meter was malfunctio., ng and showing inaccurate readings. To ensure that there was no
actual flow rate problem, Laidlaw arranged for two independent engineering firms to test the
actual flow rate in separate, tests. Those tests both reached the same conclusion — that there
was no violation, there was only a malfunctioning meter. Laidlaw has provided complete
information on this matter to the SCAQMD, which has analyzed that data and concluded that
Laidlaw is not in violation of its permitted flow rate.
a
32
Effectiveness of Laidlaw's Practice of Checking Loads for Unacceptable Wastes
Issue. One commentator indicated that he had used the landfill approximately 60
times in the last 15 years and had never once had his load checked for unacceptable wastes.
Response. Fifteen years equates to 4,650 operating days (310 days per year). As
such, 60 different visits equates to a visit on only 1.2% of all the operating days in those 15
years. Since Chiquita Canyon Landfill receives approximately 200 loads per day, the
commentator's 60 loads is only .0065 % of the approximately 930,000 loads received in that
15 year period. Since this number of loads is such a small percentage of all loads accepted,
it is not unreasonable that his loads would not have been formally checked.
It is important to note that the load check program required by the regulatory
agencies is intended to be an education and deterrent program. As such, Laidlaw has
provided information to all its contracted haulers and to the general public on acceptable and
unacceptable wastes at the Chiquita Canyon Landfill and on alternative locations for the
disposal of unacceptable wastes. The current inspection program includes a minimum of 5
random load checks per day as dictated in the solid waste facilities permit issued by the Los
Angeles County Department of Health Services. Since the inspections are random, any one
driver is not aware of when he or she might receive a formal load check inspection.
Finally, when the load check inspector is not conducting a formal inspection,
he is walking the working face of the landfill to identify unacceptable wastes. Many times,
small amounts of oil and paint are found and removed when a formal load check inspection
is not being conducted.
33
Concerns about Landfill Trash and Mud on State Route 126
Issue. Several commentators expressed concern about debris deposited on State Route
126 as a result of the landfill operations. Specifically, commentators have raised concerns
about trash being blown out of uncovered trucks as they exit the landfill. Additionally,
commentators'have stated that there is an increased quantity of mud on State Route 126 as a
result of truck traffic exiting the landfill with muddy wheels.
Response. In accordance with County policy, Laidlaw has instituted a tarping policy
at th, landfill. The purpose of the tarping is to ensure that loads with the potential to
distribute litter arrive at the landfill completely covered. Any of these loads found to be
uncovered upon entering the landfill are assessed an additional $3.00 per ton. Laidlaw
provides tarps at the gate for purchase by residential users in the event they want them for
the next load.
Laidlaw recognizes that some loads may disburse some litter on the road. As
a result, in the late 1980s, Laidlaw adopted the three miles of State Route 126 between
Interstate 5 and Chiquito Canyon Road (the entrance to Val Verde) as part of the Caltrans
Adopt -A -Highway program. As needed, either Laidlaw employees or temporary employees
from local temporary hiring agencies are used to pick up litter along State Route 126. As a
result of a fatality accident associated with the Caltrans program in Northern California,
some limitations have been placed on where we can work to pick up litter. However,
Laidlaw notifies Caltrans when certain off -limit areas need work.
Additionally, to ensure that litter will not be a problem, Laidlaw is amenable
to adopting a tarping policy that would apply to out -going as well as in -coming trucks.
Commentators also expressed concern about mud being tracked onto State
Route 126 from trucks exiting the landfill and suggested the construction of a wheel -washing
station on site. Since Laidlaw became aware that trucks leaving its facility sometimes
tracked mud onto the highway, it has regularly hired a street -sweeping service to control the
problem. Not only is Laidlaw committed to continuing this program as long as necessary,
but as a mitigation measure incorporated into the Draft EIR, Laidlaw will be paving the
internal permanent landfill roads. The effect of paving the permanent roads inside the
landfill will be a dramatic reduction or elimination of mud on the tires of exiting trucks.
34
Seismicity of the Chiquita Canyon Landfill and
Impacts of the Norduidge Earthquake
Issue. Some commentators raised concerns about the seismicity of the Chiquita
Canyon Landfill and how the landfill design responds to seismic events. More specifically,
commentators expressed concerns about how the Northridge Earthquake impacted the landfill
and how Laidlaw dealt with those impacts. Concerns were also raised about the proximity of
the Project to seismically active areas, and the landslide potential at the Project site. Finally,
commentators stated that EMCON, consultants on the Chiquita Canyon Project, are not
credible because they prepared the environmental impact statement regarding the siting and
construction of the nearby U.S. Postal Service building, which suffered damage during the
Northridge Earthquake..
Response. The entire state is within a seismic impact zone. Therefore, state
regulations require all landfills and associated structures to be designed to maintain their
structural integrity under both static and dynamic (during an earthquake) conditions,
regardless of distances to known active faults. The proposed Project is designed to meet
these regulatory requirements.
A number of statements by commentators on the subject of seismicity are
incorrect and Laidlaw wants to set the record straight.
• The Chiquita Canyon Landfill is located approximately 3.5 miles from the San
Gabriel fault, not 2 miles.
• Most areas in Southern California are bounded on three sides by faults;
therefore, the fact that Chiquita Canyon similarly is bounded on three sides is
irrelevant.
• The Holser fault is approximately 450 feet north of the northernmost area of
the proposed expansion, not 200 feet. To our knowledge, there was no
documented surface displacement or movement of the Holser fault during the
Northridge earthquake,
• The existence of what one commentator described as a "deeply buried blind
thrust fault" is purely hypothetical, No scientific documentation supporting its
existence, location, nature, or age was introduced. We know of no published
report that supports the existence of this hypothetical feature.
• With respect to comments concerning landfill gas migration along this
hypothetical fault, it should be noted that faults observed within the Saugus
Formation (the main bedrock type underlying Chiquita Canyon Landfill) are
typically filled by a clay gouge, This material has a very low permeability and
in effect would act as a barrier to gas flow, not as a conduit.
According to the EIR for Elsmere Canyon Landfill (Dames and Moore, 1995),
the San Gabriel fault is active.
35
• The epicenter of the 1971 San Fernando earthquake was located in the
basement complex of the San Gabriel Mountains, and not the Soledad Basin.
• Based on extensive mapping before and after grading within the landfill
boundaries by EMCON, and on mapping of the commercial development
immediately east of the landfill, there are no major faults which transect the
Project site. (Seward, 1989).
Several commentators specifically wanted to know how tears in the liner were
dealt with after the Northridge Earthquake. The liner tear repairs were described in
Northridge Earthquake Seismic Evaluation Chiquita Canyon Landfill, which was submitted
to the CIWMB. The report was also submitted to the Los Angeles County Department of
Regional Planning as part of the background information for the Draft EIR. In each of the
two instances where a tear was found associated with the Northridge Earthquake, the 1 to 4
feet of soil above the tear was removed by hand shovels to expose the area of the tear. The
geomembrane liner was swept and cleaned of soil debris and prepared for covering. Laidlaw
coordinated with Serrot Corporation, a recognized expert in the area of geosynthetic material
installation, to send a team to repair the tears. A similar piece of geosynthetic material was
cut to overlap the tear and it was extrusion welded to the existing liner covering all areas of
the tear. These welds were tested using the vacuum box method to ensure there were no
inconsistencies in the weld and that the new seal was continuous. The repair was ultimately
covered with soil and restored to its original grade. All this was done in coordination with,
and under the approval of, the Regional Water Quality Control Board.
With regard to the landslide comment, a landslide did occur off of the Laidlaw
site, and that matter is discussed on page IV.0-7 of the Draft EIR. The landslide mobilized
on property north of the Laidlaw leasehold with some of the material traveling onto the
Laidlaw leasehold. Since some of the soil now rests in the landfill's Cell 1 development
area, Laidlaw signed an agreement with the property owner to allow access onto their
property to allow Laidlaw to investigate and remediate the landslide and allow for expansion
development. There will be no refuse placed outside the lease boundary as a result of this
remediation. As indicated in the Draft EIR, this landslide mass will need to be removed so
that the appropriate engineered fill can be placed to support the liners necessary for landfill
development in that northern area.
In general, development of the landfill along the northern boundary of the site
will ultimately serve to stabilize these slopes by placing a buttress of soil and landfill at the
Yoe of the slopes. In the event of future seismic events similar to the Northridge Earthquake,
the chances for this type of landslide will be reduced.
Landslide potential has been addressed by EMCON's geologic mapping within
the landfill and the slope stability studies that evaluated static and dynamic conditions.
Future studies will be conducted to evaluate individual cut slopes as part of the design and
construction activities in the expansion areas.
Finally, EMCON did not prepare the environmental impact statement, nor did
it perform any other type of consulting work on the U.S. Postal Service building, and it was
36
in no way responsible for the approval or building that facility. (An EMCON employee,
Mr. Dean Francuch who spoke with the commentator, Mr. McCown, at a meeting at the
Chiquita Canyon Landfill, did work as a geologist for a former employer, and was involved
with geologic mapping and grading for the U.S. Postal Service building. This may be where
his confusion comes from.) Furthermore, the commentator has incorrectly referenced this
facility as "right on top of the [Holser] fault." The southernmost trace of the Holser fault is
approximately 2,000 feet north of the northernmost point of the Post Office property.
37
Laidlaw's Worker Safety Policy
Issue. One commentator indicated that he did not believe that Laidlaw provided its
workers with supplies like gloves and masks to protect themselves.
Response. Laidlaw's Pro -Active Worker Salty Program. At Laidlaw, worker safety
is job one. There is nothing that ranks higher on Laidlaw's list of priorities than ensuring a
safe working environment for all of its employees. In addition to recognizing its duties as an
employer and good citizen of the business community, Laidlaw knows that any business that
is careless with safety could not stay in business long.
As part of its commitment to safety, for more than four years Laidlaw has
been holding monthly training sessions focused on safety in the workplace for all of its
employees. Its goals in investing so much time and energy into such extensive safety
training are to ensure that its employees know how to respond safely to everyday events and
special situations, as well as to keep safety awareness at the forefront of everyone's thinking.
Laidlaw is very proud of its program, so to provide an idea of the depth of its commitment
to safety training, below is a list of the training sessions Laidlaw has held over the past two
years..
Year Month
Safety Training Subject
1995 October
New Safety Awards Incentive Program
September
Lifting and Back Safety
August
Chemicals and Personal Hygiene
July
Heat Stress
June
Stormwater Pollution Prevention
May
Heat Stress
April
Lifting and Back Safety
March
Eye Protection
February
Hearing Conservation and Safety
January
Lifting and Back Safety
1994 December
Housekeeping Responsibilities
November
Hearing Conservation and Safety
October
Bloodborne Pathogens in Industry
September
Lifting and Back Safety
August
How to Handle Solvents
July
Flammable and Non -Flammable Compressed
Gases
June
Trenching and Shoring
May
Hearing Conservation and Safety
April
Eye Protection
March
Stormwater Pollution Prevention
February
Respirators and How to Use Them
January
Electrical Safety
M.
In addition to monthly safety training, in March 1992 Laidlaw created an
accident review board made up of a panel of three to four onsite employees. The accident
review board is responsible for reviewing the facts surrounding any accident that occurs, and
then following up by making recommendations to management about steps that can be taken
to prevent such an accident from happening again. The panel convenes every time there is
an accident or injury. This is a forward -thinking approach to worker safety -- relying on the
workers themselves to consider what steps could make their workplace even safer -- and
Laidlaw is proud of how well its employees have performed at this important task.
Laidlaw's Excellent Sadly Record. While Laidlaw is proud of its commitment
to a pro -active employee safety training program and its accident review program, as with
anything, the proof is in the pudding. To provide a clear understanding of just how well its
innovative approach to worker safety works, Laidlaw researched its workplace injuries logs
that it maintains for the U.S. Department of Labor.. They show that Laidlaw has a superb
safety record. For the six years from 1990 through the present, the landfill has had a total of
only 11 injuries, none of which were life threatening, which comes out to an average of only
1.8 injuries or accidents per year. This is an exceptionally low accident rate, especially
when you consider that at any given time Laidlaw has between 22 to 25 employees.
Looking at Laidlaw's safety record from another perspective, in a typical year
it has about 6,000 employee days°+ -- that is 6,000 yearly opportunities for one of Laidlaw's
employees to have an accident or injury. But out of those 6,000 days of accident
opportunities, in a typical year Laidlaw has fewer than 2 accidents.
4. To compute Laidlaw's employee days, we took 24 employees as a typical number for
Laidlaw in any given year, multiplied that by a typical 5 days per week, then by a typical 50
weeks per year, which equals 6,000 employee days in a typical year.
39
Adequacy of Laidlaw's Notice Provided to the Local Community
about the Proposed Expansion
Issue. Several commentators expressed concerns about various aspects of Laidlaw's
interaction with the local community regarding the proposed landfill expansion. Specifically,
commentators have alleged that Laidlaw did not give adequate notification of the proposed
expansion to residents of Val Verde and did not invite Val Verde residents to apublic
hearing on the Project. Additionally, commentators have alleged that the Draft EIR was not
prepared in Spanish and made accessible to the Latino community.
Response. Laidlaw recognizes that public input on its Project is important, and it has
invested considerable time and resources into soliciting it. Throughout the seven years that
this Project: has been in the works and in the public eye, Laidlaw has gone far beyond all
legal requirements to ensure that the community, both English-speaking and Spanish-
speaking, has had every opportunity to participate in the decision-making process. Laidlaw
is proud of its efforts to communicate with the local community and is absolutely confident
that everyone who wanted to comment on the proposed Project has had several convenient
opportunities to do so.
As far back as 1989, Laidlaw conducted two public scoping meetings on the
proposed landfill expansion. The first meeting was held in Newhall and the second in Val
Verde. Notices were circulated in the Los Angeles Daily News and the Castaic Signal.
Many people from the community attended the meetings, including some of the
commentators. Two newspaper articles on those meetings are attached.
Concurrently with the scoping meetings, A.B. 939 became law and, as a
result, Laidlaw reevaluated the Project and decided to add three resource recovery facilities.
Based on the feedback at the scoping meetings, the passage of A.B. 939, and the addition of
the resource recovery facilities to the Project, Laidlaw began redesigning the proposed
Project and creating materials to aid in the preparation of the Draft EIR. In February 1994,
Laidlaw initiated a formal, bilingual community outreach program to share information and
get feedback on the revised proposed Project. Laidlaw's goal has been to ensure all
community members have an effective voice in the environmental review and planning of the
Project, including providing the public with accurate information about the proposed
expansion and responding to its questions and concerns.. During the 22 months since the
formal outreach effort began, Laidlaw has met with 43 groups and individuals in Val Verde
and in the neighboring communities of Castaic, Canyon Country, Santa Clarita, and
Valencia. Eleven of these meetings were with Val Verde organizations and residents.
Laidlaw made 17 presentations in Val Verde and throughout the greater community during
this time, and also conducted 16 site tours for both English- and Spanish-speaking
individuals.
From the program's inception, although not required by law, Laidlaw has
taken the initiative in preparing public information materials both in Spanish and English,
including a 10 -minute video describing the expansion, These materials were distributed to
the community by mail or at workshops and presentations. Laidlaw also had the executive
summary of the Draft EIR translated into Spanish to respond to existing and potential
09
requests for information in Spanish concerning potential environmental impacts. Even
though the Regional Planning Commission did not receive aM requests for the Spanish
document, Laidlaw mailed 60 Spanish-language summaries to interested Val Verde residents
in August. Further, although not required to do so, Laidlaw hired a Spanish-language
interpreter to provide simultaneous translations at the public hearing held in Valencia.
Continuing in this vein, at the request of the chairman of the Regional
Planning Commission Laidlaw offered free bus transportation to Val Verde residents who
wanted transportation to attend the November 30, 1995, hearing of the Commission.
Looking at these many community outreach efforts, it is clear that Laidlaw has
done far more than is required or reasonably expected of it to ensure that the public has had
many convenient opportunities to express their views on the proposed Project. These efforts,
coupled with the fact that the County Board of Supervisors extended the formal comment
period on the Draft EIR to more than six months, it is clear that the community has had
more than adequate time to review the details of the proposed Project and to comment on it.
41
/.Y, i90a9
Val Verde
skeptical
of landfill4
By CAROL CHAMBERS
Signal staff writer
Heavy trash truck traffic on highway 126 and lim-
ited expansion of other landfills were hot topics. Wed-
nesday night as Val Verde residents continued to voice
their concerns about the already unpleasant aspects of
living next door to a dump.
At issue was the proposed expansion of the teeming
Chiquita Canyon landfill which is expected to reach its
capacity by 1991.
Officials of Laidlaw Waste Systems, the operator of
the landfill, Gelded questions from some 15 residents
who attended an informal public forum in Val Verde
Park ,to "gather input and identify issues."
The landfill currently covers 128 acres east of Chi-
quito Canyon Road. if expansion pians are approved,
Laidlaw hopes to add an additional 128 acres, doubling
the size of the dump and adding another 15 years to its
life, officials said.
Several proposals were put forth to help assuage on-
vironmental fears, among them recycling and
composting..:-
"We would establish a drop-off center for bottles,
paper and aluminum cans," said Kevin Carcl, a Laidlaw
spokesman, adding that provisions for hazardous
household waste such as solvents and pesticides would
also be established.
By recycling, Carel said, the effective capacity of the
landfill could be stretched by several years.
Although a new composting process that could pro-.
vide electricity forsome 15,000 homes is being consid-
ered for the landfill, Laidlaw officials said the cost of
producing the energy would stiiIl make the process
prohibitive.
If approved, the expanded landfill 'will occupy 48
million cubic yards of airspace. Of that volume, l0 mil-
lion tons of landfill space has been reserved by The Ne-
whall Land and Farming Co.
But despite assurances, some Val Verde residents
voiced their skepticism about giving a community-
wide nod to doubling the size of the dump.
"I'm concerned about t:,e closing of so many other
landfill sites," said Calvin Lujan, a two-year Val Verde
resident.
"Why should we approve expansion here when we
don't limit the influx from other places," he said, ad.
ding. "It might. be like cutting out own throats.
"But the real problem now — right now — is the
truck traffic," Lujan said. His Statement was echoed by
ncsrly.all in attendance. '
a� aja4
spt�
fvy(eA
Sjj`P74/ �qne .79 19?19
i 7
Lan dfiff-S6kp' ansion `discussed
Continued from Page. 1, 1:;*". Verde Association, ques
Civic.1 I 'causd residents frequently reported
l.;._.
canyons are also in the - planning Boned the .landfill's legal' acccp�j - that they would become dizzyIrgin
stages by, -,public and,private tance:.of'sludgz`(a treated by.;xtthesrncIL*;-
0 . . .. I -
operators. product of sewage) and the accom7q. ". •_-Projects have gotten started In
Me landfill; takes about 2,5001 panying smell. good faith and as the years roll ar-..
tons of garbage each day from 400 f "Seven hundred thousand'[ - ound,'Lhey end up. being murder
trucks from all over the county but pounds of that sitting, steaming in ers." he said.•
is permitted to accept 5,()00 tons of - the z SUU . i3l'110t what. we, want to:.' -Brown said the 400 dump tnicks
garbage per day. It has applied to' .,
per day created a serious traffic hall
double that permitted daily intake.-
ke. I Beni said his group was unwillm; zard as they lined up on the shoulder
Landfill operators . said they were I. 'Ing to endorse thelandfill unless its '4 -of Highway 126 waiting toenter the
willing to reserve the last 10million, operators would submit a plan to in. •
landfill and as they cromd the;
cubic yards of the landfill's capac.: crease trash recycling in the SC _ 'highway to exit.
itY for the Santa. Clarita Valley's r. 1 Edwin 'Seth'Brown,' also of , the ;S;4, He and others noted thb recent
garbage, extending its use here ab- Val Verde Civic Association, said 1,.-, . case in which fixe leca-agas-w=
out 30 years. were cautious he and his neighbors Ella ured when their truck was struck
Low Berti, a member of theVal"A about the landfill's expansion be- b a trash truck leaving the dump.
I r1ro."UrLorra GVE
jqndfill
k
weighed
Residents discuss
expansion, of. dump
An Chiquita Canyon
ir By SHARON HOWELL
Signal staff writer
Residents of Val Verde who
ready--i-ftiptain
co
Sewage odocLkom Chiquita Cal.
yon
IanAMI Spent much of Wed-
esday night grilling company offi-
cials about plans to double the
dump.
: The 25 people attending a meet-
irig at the SCV Senior Center pep-
pered Laidlaw. Waste Systems Inc.
employees and consultants with
t' -.questions about potential water
contamination, truck 'traffic on
Highway - 126 and grading' next to
P the road.," ,.-- � ' I . .
The landfill Is tow opia2ted an
128 ages on a ridgeline cut of Val
Verde's Chiquito Canyon Road and
would. be expanded to about 336
acres if company plans are success-
fw. it is owned by The Newhall
Land-ine Farming Co.. but no Offi-
cal of that company attended the
meeting.
The expansion of Chiquita Ca-
P'ohindfill is one
c 01 four dumps s
posed 'orticSCVinth next
few
M.SnshineC;yon lad -
f
l
has applied forex
ion and
land Ils creand Towslcy
- Continued on Page 16
Project Impacts on Riparian Habitat Associated with
the least Bell's vireo
Issue. Commentators have indicated that the Draft EIR does not address the riparian
habitat associated with the least Bell's vireo.
Response. The biology analysis contained in Section IV.B recognizes the riparian
habitat in the Santa Clara River drainage system that contains critical habitat for the least
Bell's vireo (pp. IV.B-10 through IV.B-11) The Project site is situated more than 1,010 feet'
north of the nearest potential habitat area. It is not known whether any birds have been
sighted in the closest. habitat. Nonetheless, none of the expansion plans or improvements
proposed onsite would directly impact those offsite habitat resources. Therefore, the Draft
EIR concludes there will be no significant impacts to the bird or its habitat.
42
The Handling of Sludge in the Composting Facility
Issue. Some commentators raised concerns about the handling of sludge in the
proposed composting facility. Those concerns include the proposed composting method and
the possibility of odor from sludge used in composting. Additionally, several individuals
commented on composting technologies and stated that the Bedminster technology utilized at
the Las Virgenes Municipal Water District operation in Calabasas should be used at Chiquita
Canyon.
Response. Windrow Composting Is A Scientifically Proven Process. There are two
broad categories of composting methods: windrow systems and in -vessel systems. The
Project proposes to use a windrow composting system, through which it will receive,
process, and compost yard waste and nonhazardous, municipal wastewater biosolids. The
yard waste will be inspected before being fed to a shredder. Two fractions will be produced,
fines which will be composted, and chips which will either be composted or sold as mulch or
fuel. The material to be composted will then be placed in windrows and the biosolids will be
added. A compost turner will blend the materials on a regular basis to maintain aerobic
conditions, manage the compost process, and control odors. During the composting process,
the compost windrows' temperature, moisture content, and oxygen content will be monitored,
and the turning frequency will depend on the results. After about 90 days, the composting
will be completed, and the finished compost will be distributed. This windrow process is
widely used and, with good management practices, does not present any odor problem.
Biosolids Are Important To Good Composting. Wastewater biosolids are
important to the composting process. Yard waste requires additional moisture to achieve
good composting conditions. Biosolids provide a good source of moisture, as well as an
exceptional source of nitrogen. If biosolids were not used, water from some other source
would be needed to provide moisture, which makes no sense in drought -prone Southern
California, and even then the compost would be inferior to amore nitrogen -rich compost
made with biosolids.
In Vessel Composting Offers No Advantages And Costs Much More. In -vessel
composting is similar to the windrow process, but it uses an enclosed or semi -enclosed
environment for the composting process. An example of an in -vessel system and one that
several commentators have referenced is the Bedminster system. While both systems are
effective, there is nothing inherently superior about either one. Windrow systems are in
wider use than in -vessel systems, and both methods require that the composting facility be
well-designed and well-managed. With poor management, either method can result in
operational problems, such as odor or an inferior finished product.
The Las Virgenes Municipal Water District (LVMWD) has an in -vessel
composting facility that some commentators mentioned. That facility is a good facility that
makes use of biosolids generated by LVMWD's wastewater treatment plant. However, that
facility is not an appropriate comparison to the composting facility proposed for the Project.
For example, during interviews LVMWD explained that LVMWD's capital investment in the
facility was approximately $50 million -- a sum far in excess of anything that could be
considered at Chiquita Canyon. That $50 million sum was paid by a bond issuance that
43
LVMWD was able to issue because it is a government agency. Further, operational costs of
the facility are funded by rate increases to LVMWD's ratepayers.
Obviously, a financial commitment along the scale of LVMWD's composting
facility cannot be considered at Chiquita Canyon. Even assuming that everything went
perfectly, the capital cost alone spread over the life of the facility would come out to $50 per
ton of compost. Without even considering the operational costs, such a facility could not
hope to survive in the open market. Moreover, there is absolutely no reason even to
consider such a facility at Chiquita Canyon, because a well-run windrow composting
operation will work very well, be more cost-effective, and will not cause odor problems.
MI
The Fairness of Sludge Disposal at Chiquita Canyon
Issue. Several commentators from Val Verde have stated that they do not contribute
to sewer sludge in Los Angeles County because they are on septic tank systems. Those
commentators have suggested, therefore, that no sewer sludge should be disposed of at the
Chiquita Canyon Landfill.
Response. Based on interviews with several of the septic tank maintenance companies
in the Santa Clarita Valley, it is clear that the community of Val Verde contributes to the
sewer sludge in the county, just like everyone else. This is because after a septic tank
maintenance company pumps a septic system at a residence in Val Verde, it takes the raw
sewage to one of two locations: either the Los Angeles Sanitation District's, Plant No. 26,
in Santa Clarita, or the treatment facility in San Fernando. Both of these plants take the
septic tank pumpings and treat them for disposal or reuse. In this way, eventually, the septic
tank pumpings from Val Verde make it into the public treatment system, and the sludge that
is created as a result must be disposed of or reused just like everybody else's.
45
Breakdown of Fees Generated By the Project
Issue. Some commentators noted that Laidlaw stated that the proposed Project would
yield approximately $100 million in direct tax revenue to Los Angeles County over the life
of the Project. Some Commissioners indicated that an explanation of this figure would be
helpful.
Response.. At the first Regional Planning Commission hearing on the proposed
Project, Laidlaw informed the Commission that the project, if approved, would yield
approximately $100 million in tax payments directly to the County. That figure was
computed as follows. The proposed expansion of Chiquita Canyon Landfill would enable the
landfill to accept approximately 29 million tons of additional waste (see p. 1-3, Table 1-1 in
the Draft EIR). Assuming that Laidlaw earns $25 in revenue on each ton of waste disposed
at the Landfill, the combined effect of the Los Angeles County business license tax and two
additional county fees means that the proposed Project will generate over $100 million for
Los Angeles County. The Los Angeles County business license tax at the time of the first
Commission hearing was 10% of the landfill's revenue from waste disposal. Over the life of
the proposed Project, this would have amounted to $72.5 million. That money goes directly
into the County's General Fund. Additionally, there are two other County taxes, a $.86 per
ton fee paid to the County Department of Public Works, and a $.14 per, ton fee paid to the
County's Department of Health Services. Combining these three taxes, but not counting any
other State and Federal taxes that must be paid, the County would have directly received
$101.5 million,from.the proposed. Project.
Since that first Commission hearing, however, the County Board of
Supervisors has increased the landfill business license tax by 50% (raising it to 15% of waste
disposal revenues), and has created a new "tipping fee" tax of $.25 per ton paid directly to
the County's General Fund. These new and increased taxes went into effect on October 1,
1995, so the $100 million figure described above is outdated. Accounting for the new taxes,
the proposed Project would yield directly to the County approximately $145 million over the
life of the Project.
EM
Necessity of DMS Compliance
Issue. One commentator stated that all conditional use permits must have "DMS
compliance" and that the Draft EIR for the Chiquita Canyon Landfill expansion does not
address the issue of such compliance.
Response. "DMS" refers to the County's Development Monitoring System. The
DMS is the means by which the County monitors the capacity of various infrastructure
systems to accommodate growth. The DMS is applicable only to urban development
projects, particularly residential projects that constitute an urban expansion (i.e., projects
which involve a general plan amendment from non -urban to urban and/or a change of zoning
to permit urban residential densities). It is not applicable or relevant to conditional use
permits for landfill expansion projects, such as Chiquita Canyon, in a non -urban area and in
which no general plan amendment or change of zoning is required or requested.
W