DATE: December 15, 2015
TO: Board of Supervisors
SUBMITTED BY: Alan Weaver, Director
Department of Public Works and Planning
SUBJECT: American Avenue Disposal Site Phase I Clean Closure
RECOMMENDED ACTION(S):
TITLE
Authorize the Director of the Department of Public Works and Planning to issue an RFP for the American Avenue Disposal Site Phase I Clean Closure Work Plan development and regulatory approval.
REPORT
Approval of the recommended action provides for the development of a Clean Closure Work Plan (CCWP). The Work Plan must be developed and approved by regulatory agencies prior to commencement of clean closure construction activities. This action will initiate the clean closure process of American Avenue Disposal Site Phase I within a schedule developed with County input and consideration. The waste within Phase I will ultimately be placed in a lined waste management unit (WMU) within the American Avenue Disposal Site (AADS) and then the Phase I area will be lined and filled with future incoming waste.
ALTERNATIVE ACTION(S):
No viable alternative exists. Failure to Clean Close American Avenue Disposal Site Phase I subjects the County to potential Notice of Violations (NOV), a Cease and Desist Order (CDO) and a compliance schedule for clean closure that is unilaterally developed and imposed by regulatory agencies.
FISCAL IMPACT:
There is no net County cost associated with the recommended action. The recommended $15,000,000 is available through the AADS Fund 0700, Subclass 15000, Org 9026, Account 8150. Sufficient appropriations are available in the current FY 2015-16 Adopted Budget for this action and will be requested in subsequent year’s budgets.
DISCUSSION:
The County of Fresno owns and operates the AADS, which is located approximately 26 miles west of Fresno on American Avenue. Phase I is a 30 acre inactive, unlined WMU that contains Class III municipal solid waste and is located in the area of future Phase III Modules 11 and 12, please refer to Attachment A. There are 11 temporary landfill gas (LFG) extraction wells in Phase I which are connected to the landfill gas collection and control system (LFGCCS). Phase I does not have a leachate collection and recovery system (LCRS) to remove leachate from the unlined cell.
Absence of a liner and a LCRS increases the potential impact to groundwater from leachate and LFG. Analysis of samples from groundwater monitoring wells adjacent to and down gradient of Phase I have detected volatile organic compounds (VOC’s). These detections required completion of an Evaluation Monitoring Program (EMP), Engineering Feasibility Study (EFS) and a Corrective Action Program (CAP) in accordance with California Code of Regulations Title 27 (CCR 27). The County retained ARCADIS to develop the EMP/EFS/CAP and submit the required documents to the California Regional Water Quality Board (RWQCB).
The EMP/EFS/CAP determined that the previously mentioned VOC’s detected in ground water samples are derived from LFG present in Phase I. The CAP proposed that the VOC’s be reduced in concentration by natural diffusion into the surrounding soil in conjunction with LFGCCS best management practices (operation in accordance with the Permit to Operate and the Solid Waste Association of North America’s Landfill Gas Operation & Maintenance Manual of Practice) as the remediation method to satisfy the requirements of CCR 27. The RWQCB concurred with the proposed CAP developed by ARCADIS on behalf of the County and incorporated the plan into the most recent Waste Discharge Requirement (WDR) No. R5-2012-0064 (adopted June 8, 2012) as Condition Number 45.
The County’s intention to excavate waste located in Phase I appears as Condition Number 61 in the current WDR No. R5-2012-0064. Condition 61 states “The Discharger [County of Fresno] proposes to excavate the existing inactive unlined waste management unit (Phase I) and place the excavated waste into a composite lined landfill cell. Excavation of the unlined unit will continue until all wastes within the unlined waste cell are removed. The Discharger proposes to construct a composite liner system in the place of the former unlined waste management unit contiguous with existing Phase II and future Phase Ill modules, once the unlined unit has been excavated and the area is prepared for operations.”
Since the current AADS WDR states that the County proposes to excavate the existing inactive unlined WMU (Phase I) and place the excavated waste into a composite lined landfill cell, failure to undertake this task may result the issuance of NOV’s and a subsequent CDO by regulatory agencies. Initiation of the AADS Phase I Clean Closure prior to receiving an NOV or subsequent CDO will allow the County to work within a schedule developed by the County instead of a schedule unilaterally developed and imposed by a regulatory agency. This action may also save the County money since there will not be a need to expedite the clean closure process in order to meet a deadline unilaterally imposed by a regulatory agency.
This project is a component of the financial plan developed with the City of Fresno and the City of Fresno is aware of this agenda item.
ATTACHMENTS INCLUDED AND/OR ON FILE:
Attachment A
On file with Clerk - American Avenue Disposal Site WDR No. R5-2012-0064
CAO ANALYST:
John Hays