HomeMy WebLinkAboutMINUTES - 10271992 - 2.5 2 . 5
TO: BOARD OF SUPERVISORS
Contra
FROM: HARVEY E. BRAGDON t
Cosa
DIRECTOR OF COMMUNITY DEVELOPMENT L
DATE: OCTOBER 12 , 1992
County
SUBJECT: DIRECT HAUL TO KELLER CANYON LANDFILL
SPECIFIC REQUEST(S) OR RECOMMENDATIONS) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
1. Accept the staff report.
2 . Accept the . staff recommendations for interpreting Land Use
Permit 2020-89's Conditions of Approval specifying vehicles
and loads eligible for direct access to the Keller Canyon
Landfill, and specifying a process for considering direct
access requests.
FISCAL IMPACT
Implementation could result in some improvement in the collection
of regulatory fees and administrative charges.
BACKGROUND/REASONS FOR RECOMMENDATIONS
On August 11, 1992, the Board of Supervisors requested staff to
propose criteria for enabling qualifying industries to haul direct
to the Keller Canyon Landfill. The Board's request coincided with
a request from Supervisor Torlakson (dated August 1 1992) to
staff for similar information.
CONTINUED ON ATTACHMENT: YES SIGN ATU
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION F BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S) :
ACTION OF BOARD ON 7 /y9.�2 APPROVED AS RECOMMENDED X OTHER ,Y _
The Board approved the above recommendations and added the following:
3. REQUESTED Director of Community Development to prepare a letter to the
editor, as well as an information sheet for distribution to the public,
summarizing the reason why direct access to the landfill by the public is not
allowed.
4. ENCOURAGED staff to work further with the Keller Canyon Landfill owners,
local industries and haulers to determine if there are reasonable proposals for
direct haul of certain industrial waste in a way to reduce hauling mileage and
air pollution, as well as costs, whether through a land use permit amendment or
through a "special waste" designation or other reasonable approach.
5. REFERRED this matter to the Keller Landfill Citizens Advisory Committee
for review. I HEREBY CERTIFY THAT THIS IS A
UNANIMOUS (ABSENT TRUE AND CORRECT COPY OF AN
AYES: NOES: ACTION TAKEN AND ENTERED ON THE
ABSENT: ABSTAIN: MINUTES OF THE BOARD OF
SUPERVISORSON THE DATE SHOWN.
Contact: Charles Zahn (510/646-2096) ATTESTED (JS%/�� ' 4Z,t- -)7, /LLL
cc: Community Development Department (CDD) PHIL BATCHELOR, CLERK OF
County Counsel THE BOARD OF SUPERVISORS
Health Services Department (C. Nicholson) AND COUNTY ADMINISTRATOR
Public Works Department (J. Causey)
Acme Fill Corporation (via CDD)
Keller Canyon Landfill Co. (via CDD) BY E , DEPUTY
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Direct Haul to Keller Canyon Landfill
•Continued - Page 2
Context
The Conditions of Approval for Land Use Permit 2020-89 require
waste to be delivered to a transfer station and to be transported
to the landfill in transfer vans. Specific exceptions are provided
for certain demolition/construction material loads, incinerated
sludge loads, utility sludge loads, designated waste loads, and
specialized waste loads (as identified in the Solid Waste
Facilities Permit) . These exceptions are for wastes which are
inappropriate for transfer station operations and which typically
require special handling at the landfill.
There is no specific exemption for industrial loads, but some
industrial wastes are classified as designated wastes or special
wastes requiring transport in specialized vehicles and special
handling at the landfill.
Barring direct haul to the Keller Canyon Landfill mitigated
traffic, noise, and air quality impacts in the vicinity of the
landfill. A major concern is that amending the permits to allow
some industries to haul transferrable wastes directly to the
landfill make it difficult to deny direct access to others.
General Access Criterion
The general landfill access criterion, frequently stated at past
public meetings on the Keller Canyon and Marsh Canyon landfills, is
that wastes which can be processed through a transfer station
should go to one. The general criterion recognizes that some
wastes are restricted from being taken at a conventional transfer
station (e.g. designated wastes) but can be disposed at an
appropriate landfill, while other wastes cannot practicably be
processed at a transfer station (e.g. sludges and ashes) . Another
aspect of the general criterion is that transfer stations'
capabilities (or alternative recycling facilities' capabilities)
are expected to change over time, enabling them to handle more
kinds of wastes. An example is construction debris which formerly
was landfilled but which is now being chipped (wood) , crushed
(concrete) , and sorted for recycling (metals) to an extent not
envisioned only a few years ago.
Rationale For Minimizing Direct Haul
Early in the 1981-1992 effort to obtain long-term landfill capacity
for Contra Costa County, it was recognized that landfill traffic
was one of the major impediments -- probably the major impediment -
- to siting a new landfill. The sheer numbers of vehicles
involved, the high percentages of trucks, high noise levels,
traffic-related air pollution, and littering weighed against the
conventional practice of direct landfill access. As a consequence,
the concept of using transfer stations (preferably located at
already-impacted landfill sites) to absorb traffic impacts was
evolved during our County's siting process. Until then, transfer
operations were justified mainly for economy-of-long-haul reasons.
In addition to reducing traffic in the vicinity of a new landfill
to up to one-tenth of conventional direct access vehicular volumes,
several additional reasons became important as the landfill siting
effort progressed. Those included:
the transfer station concept evolved into the transfer
station/material recovery facility/composting facility/and
household hazardous waste facility concept as core facilities
for meeting County Solid Waste Management Plan, and then the
Integrated Waste Management Plan, resource recovery
obligations.
- hazardous waste inspection and elimination of ineligible loads
were readily accomplished at the gate and concrete tipping
Direct Haul to Keller Canyon Landfill
Continued - Page 3
floor of the transfer station. The waste subsequently
received at the landfill generally was ready for immediate
disposal.
- managing the working face and the on-site access road of the
landfill became predicated on minimizing the number of
vehicles to be accommodated. The Solid Waste Facilities
Permit for .the Keller Canyon Landfill limited the entire
working face to only one acre. The BAAQMD permit to operate
specified that the on-site road had to be sprinklered after
every fifth truck as a means of particulate control. With the
addition of working face dust and litter control requirements,
smooth disposal operations became a matter of coordination
between experienced landfill crews and knowledgeable waste
truck drivers (all transfer vans to this point) .
Adherence to specified haul routes and peak hour restrictions, as
well as littering attributable to transport vehicles, were
virtually eliminated as problems associated with the Keller Canyon
Landfill with the elimination of occasional users.
As of this writing, the waste hauling trucks on Bailey Road have
numbered about 60 transfer vans on an average weekday. There have
been no instances of vehicles straying off the designated haul
route. Operations at the working face have been exemplary.
Direct Haul Policy
Pursuant to the adopted Land Use Permit and Solid Waste Facilities
Permit, staff recommends that wastes which cannot legally or
practicably be processed through a transfer station may be
considered for direct haul to the Keller Canyon Landfill. Such
wastes include:
Heavy or Massive Materials
Example. Large (e.g. 10 ton) reinforced concrete slabs.
Reasons. The material could damage the self-unloading mechanisms
or thin walls of transfer vans, especially during drop loading.
Recyclability. Concrete is increasingly being crushed and re-used
as construction material. The size of large slabs and the presence
of reinforcing rods make crushing of some slabs very difficult.
Transport. Usually accomplished with large flat-bed or dump-body
heavy construction trucks.
Special Handling. Slabs must be individually placed on the working
face to not endanger the liner or leachate or gas collection
systems, or to avoid disruption of fill and cover operations.
"Wet" Materials
Examples. Utility sludges and industrial process slurries and
residues. (Exceptions: liquid wastes, which are prohibited, and
state-designated wastes, including some sludge and drilling mud. )
Reasons. Semi-solid materials are not readily moved with bladed
vehicles at the transfer station, and may "leak" into loading bays
and other equipment. °
Recyclability. Varies widely. In the future, organic sludge may
be extensively used in co-composting processes, but the materials
now are disposed by landfilling or land spreading (used as
fertilizer) .
Transport. Semi-solid materials must be transported in lined
vehicles to avoid leakage.
Direct Haul to Keller Canyon Landfill
'Continued - Page 4
Special Handling. Semi-solid wastes are directed to particular
discharge locations on the landfill face and discharged under
surveillance.
Comments. 1) Minimum solids content regulations apply to sludge
discharged at the landfill. "Wet" materials must be de-watered to
consist of at least 50% solids to be taken at the Keller Canyon
Landfill. 2) In the future, certain sludges will be directed to
the composting operation of the transfer station/materials recovery
facility.
Powdery or Granular Materials
Examples. Ash or industrial process materials, such as dry filter
cake.
Reasons. Similar to those listed for "wet" material
impracticability for movement and loading at the transfer station) .
Recyclability. Varies widely. Typically, resource recovery would
be accomplished at the plant of origin. Certain ashes and
industrial materials may be used in composting, particularly as
bulking agents. Some are used in land spreading operations as
fertilizer or soils amendments.
Transport. Usually transported in enclosed vehicles to avoid blow-
off or littering.
Disposal . Special handling, such as location of discharge and
immediate covering at the landfill may be required to prevent the
creation of dust or road tracking.
Comments. 1) Hazardous or toxic materials are prohibited. 2)
Designated wastes must be handled as such.
Designated Wastes
Examples. Any solid or semi-solid waste, including some utility
sludges and ashes, identified as a designated wastes by the State
Regional Water Quality Control Board.
Reason. Designated wastes cannot be processed at the Acme Transfer
Station.
Recyclability. Resource recovery would be accomplished at the
plant of origin.
Transport. Varies with material.
Disposal . Individual designated waste loads require special
handling at a landfill.
Comments. Designated wastes must be disposed at a Class II (or
Class I) landfill. Keller Canyon is a Class II landfill.
Special Wastes (Other Special Handling Wastes)
Examples. Examples range widely from auto bodies to dead animals.
Reason. The reasons why transfer stations do not take special
wastes, vary with the waste itself. Landfills may not take certain
of the wastes either. Auto bodies are bulky. Dead animals may be
disposed in trenches, which are immediately covered, but typically
are taken to other facilities.
Recyclability. Varies widely. Some are not accepted at solid
waste facilities but are taken to other kinds of facilities, such
as auto salvage yards. Dead animals, such as road kill, are now
typically sent to rendering plants.
Direct Haul to Keller Canyon Landfill
•Continued - Page 5
Transport. Varies with material.
Disposal . Individual special wastes accepted by landfills require
their own disposal arrangements.
Policy For Resource Recovery And Waste Inspection
Staff recommends that current direct haul permit conditions remain
in force. We are willing to give further consideration to amending
the Land Use Permit to allow industries to originate transfer van
loads under tightly controlled circumstances (see page 6) .
Traffic reduction and haul route control on Bailey Road have been
successful. The management of the working face of the landfill has
proceeded as envisioned by the Project Description and
Environmental Impact Report.
The new County Integrated Waste Management Plan envisions that
three sub-regional transfer station/materials recovers facilities
(The West Contra Costa Integrated Resource Recovery Facility, The
Acme Resource Recovery and Transfer Station and the East County
Community Collection Center) , will be the core facilities for
achieving AB 939 objectives. These would be complemented by
certain new facilities as well as by traditional enterprises such
as wood chipping, concrete crushing and metal salvage yards. It is
important that recoverable waste not avoid the transfer
station/materials recovery facilities and that source-sorted wastes
be sent to recovery facilities (alternatively, waste materials can
be subject to intensive recovery where they are produced) . Where
appropriate to the circumstances, the Community Development
Department will request prospective direct haulers to submit
studies demonstrating that the waste materials are not recyclable
or copies of the waste originator's in-house waste reduction and
recycling programs.
As noted, until recently, it was thought that there would be a
demand for large construction and demolition loads to be sent to
the landfill. Consequently, the Land Use Permit Conditions of
Approval for the landfill call for the ultimate installation of
wood chipping equipment and the conduct of a pilot program leading
to a composting program. Increasingly, however, construction wood
is being sent to chipping facilities, concrete and asphaltic
pavement is being crushed, and large yard waste streams are being
composted. There is diminishing need for chipping and composting,
and maybe later crushing, at the landfill. Staff would prefer to
postpone or possibly avoid the need for these additional sources of
noise, dust, and odor at the landfill. Staff, therefore, proposes
to evaluate requests for direct haul in terms of the circumstance
of chipping, crushing, and composting at the transfer
station/materials recovery facilities or at alternative facilities.
Waste inspection ("lay-out and look-at") for hazardous and toxic
materials on a paved surface is an important function of a transfer
station. Where appropriate to the circumstances, staff will
request prospective direct haulers to submit alternative waste
inspection programs as part of the review process.
Policy For Determining Eligibility For Direct Haul
Process
In addition to waste generators who believe that their regular
waste streams qualify for direct haul, there will be instances of
unusual or one-time wastes which will need to be evaluated for
eligibility in the future.
Staff recommends that waste generators who want their waste
considered for direct haul to the landfill shall request an
eligibility determination from the Keller Canyon Landfill Company.
Direct Haul to Keller Canyon Landfill
•Continued - Page 6
Direct haul may be authorized by the County Community Development
Department if it determines that the request complies with the
Keller Canyon Landfill's Land Use Permit and the direct haul policy
articulated above, and the County Health Services Department has
determined that the request is in compliance with the Landfill's
Solid Waste Facilities Permit.
The Keller Canyon Landfill Company will contact the Acme Transfer
Station (or other transfer station) to ascertain whether the
transfer station would process the material either for trans-
shipment to the landfill or accept it as a recyclable (e.g. for
diversion to its composting facility) . Keller will also determine
whether the material can be accepted at the landfill in accordance
with the Company's own rules and regulatory agency permits. Keller
will notify the Community Development Department and Health
Services Department of the request and its findings. If the
Company finds that the transfer station, or its associated
composting or other resource recovery operation, cannot take the
material and that the landfill can receive it, the Community
Development Department may authorize direct haul after determining
that there is no appropriate alternate resource recovery facility
(e.g. , crushing plant for concrete) to send the waste to and that
the Health Services Department has found that direct haul would be
consistent with the Landfill's Solid Waste Facilities Permit.
Keller Canyon Landfill Company Conditions and Charges
The Keller Canyon Landfill Company may impose conditions on direct
haulers provided that the conditions do not conflict with the
County's Land Use Permit Conditions of Approval. The Company, for
example, may require direct haulers to contract for landfill use,
to submit qualifying and periodic laboratory tests, to have waste
inspection and quality control programs in effect at the plant of
origin, to train drivers in landfill procedures, to comply with on-
site traffic control, and to approve waste hauling vehicles.
Materials and loads requiring special handling may be subject to
additional charges. In addition, the County expects that the
private-sector conditions will require the direct hauler to observe
certain Land Use Permit Conditions of Approval such as using
specified haul routes and observing traffic peak-period
restrictions.
Regulatory and Program Fees and Charges
Private sector charges (processing, transhipment, and disposal) and
public sector charges (most regulatory fees and program charges)
are imposed on commercial and self haulers at the transfer station.
Charges for direct haul loads would have to be collected at the
landfill. The normal landfill "rate" , however, does not include a
number of regulatory fees and public program charges which are
imposed through the transfer station "rate" but which are still
applicable to the processing and disposal of wastes. These include
the Local Enforcement Agency fee, tipping fee surcharge for city
and county AB 939 programs, a county recycling charge, and possibly
costs for closing old landfills. These are appropriately collected
at the landfill. Certain other charges, such as staff plant
inspections and reviews of the generators' quality control and
plant recycling programs would be charged directly to the waste
generator.
Consideration of Industrial Establishment High-volume Direct Haul
Provisions
The Land Use Permit conditions do not address the contingency that
a particular industrial plant might be able to amass 20-ton loads
of ordinary wastes and be willing to subject the material to
County-approved in-plant recycling and quality assurance programs,
to transport it to the landfill in approved self-unloading transfer
van vehicles, and to comply with haul route and peak-hour
Direct Haul to Keller Canyon Landfill
'Continued - Page 7
restrictions. There would, therefore, be no net increase in the
numbers of vehicles traveling to the landfill. If enabled to have
direct access to the landfill, the waste generator also should be
obligated to pay regulatory and program fees on charges otherwise
paid at the transfer station. These include the tipping fees and
charges described above. In effect, the waste generator would
perform many of the functions of a transfer station facility and be
subject to the public agency charges imposed on transfer station
facilities. Implementing this kind of a limited direct haul
program for high-volume industrial plants would require amending
the Land Use Permit and the Solid Waste Facilities Permit.
No generator has actually studied and proposed such a direct haul
arrangement to warrant additional staff work although at least one
has expressed an interest.
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