HomeMy WebLinkAboutMINUTES - 06201995 - D7 w
1
TO: BOARD OF SUPERVISORS _ }
FROM: VAL ALEXEEFF, DIRECTOR, .� Contra
GROWTH MANAGEMENT & ECONOMIC DEVELOPMENT AGENCY !` costa
DATE: June 20, 1995
SUBJECT: CRITERIA FOR REVIEW ON KELLER CANYON LANDFILL
LAND USE PERMIT (LUP 2020-89)
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS:
1. Accept the staff submittal entitled Outline of Criteria, Review of Land Use Permit Conditions
for Keller Canyon Landfill (Attachment 1).
2. Adopt criteria for the review of the Keller Canyon Landfill Land Use Permit Conditions of
Approval at the Board meeting of June 20, 1995.
3. Refer the Conditions of Approval for the Keller Canyon Landfill Land Use Permit to the County
Planning Commission for review pursuant to the Board's review criteria.
4. Direct staff to prepare a staff report on the above referred for consideration by the County
Planning Commission.
FISCAL IMPACT
No General Fund impact. The review will be paid for by the permittee as a Land Use Permit
Implementation/Mitigation Monitoring Program (I/MM) cost. .
BACKGROUND:
The Board of Supervisors, on June 6, 1995, determined that a review of the Keller Canyon Landfill
Land Use Permit Conditions of Approval should be performed through a referral to the County Planning
Commission. Accordingly,.the Board directed staff to prepare criteria to guide the review and to have
the criteria considered by the Board at a public meeting. Staff's submittal is the attache ocument
entitled Outline of Criteria, Review of Land Use Permit Conditions for Keller Canyon Lan ill. /
CONTINUED ON ATTACHMENT: X YES SIGNATUE-
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF 50ARIPCOMMITTEE
APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON June 2U, 1199D APPROVED AS RECOMMENDED x OTHER x
Following presentation by Dennis Barry, Community Development Department, of the report on
the above matter, and Board discussion of the issues, IT IS BY THE BOARD ORDERED that the
recommendations 1,2,3, and 4 are APPROVED: AND THE City of Pittsburg and Browning Ferris
Industries are INVITED to discuss whether to activate the Keller Canyon Landfill Advisory
Committee or another process for community/citizen im ut in this process; and DIRECTED
the Growth Management and Economic Development (GMEDA) staff to address the issue of
definitions of classifications of waste.
VOTE OF SUPERVISORS
x UNANIMOUS (ABSENT I HEREBY CERTIFY THAT THIS IS A TRUE AND
AYES: NOES: CORRECT COPY OF AN ACTION TAKEN AND
ABSENT: ABSTAIN: ENTERED ON THE MINUTES OF THE BOARD
OF SUPERVISORS ON THE DATE SHOWN.
i
Attachment:
ATTESTED June 20, 1995
Contact: Charles A. Zahn (510) 646-2096 PHIL BATCHELOR, CLERK OF THE
cc: Community Development Department(CDD) BOARD OF SUPERVISORS AND
County Administrator COUNTY ADMINISTRATOR
County Counsel
County Health Services Department
Central and East County Cities
Central County Waste Management Authority
Browning-Ferris Industries BY: CL , DEPUTY
Citizens' United
VA:CAZ:rw
RMACL-Crit.bod
ATTACHMENT 1
OUTLINE OF CRITERIA
REVIEW OF LAND USE PERMHr CONDITIONS FOR
KELLER CANYON LANDFILL
PART I
BACKGROUND FOR REVIEW
A. AUTHORITY
1. Land Use Permit
Condition 11.1 of Land Use Permit 2020-89 states the following:
11.1 ADMINISTRATION
Permit Review. The Board of Supervisors will hold annual public hearings to
review the Conditions of Approval for this Land Use Permit for three years
beginning one year after the commencement of operations of the Landfill. The
Board may refer proposed changes to the Land Use Permit to the County
Planning Commission for processing. Thereafter, the County Planning
Commission shall hold public hearings on the Land Use Permit at three-year
intervals. As a result of a review and public hearing, the County Planning
Commission may recommend to the Board of Supervisors new or modified
conditions to improve the public health, safety, and welfare. Nothing in this
condition shall preclude the landfill owner from applying for amendments to the
Land Use Permit at any time or preclude the County from addressing emergency
situations or new requirements imposed by State or Federal legislation or the
courts.
2. Intent of Review
B. CONTEXT FOR THE REVIEW
1. Applicable Laws and Regulations
Page 1 -
2. Terms of Applicable Permits
a. Solid Waste Facilities Permit (LEA)
b. Waste Discharge Requirements (RWQCB)
C. Permit to Operate (BAAQMD)
d. Other Regulatory Agency Requirements
3. Compliance with CEQA; Consistency with Keller EIR
4. Vested Rights of Permittee
5. Demonstration of Compelling Public Necessity
C. STATUS OF EXISTING LAND USE PERMIT CONDITIONS OF APPROVAL
(IMPLEMENTATION/MITIGATION MONITORING PROGRAM)
D. COMPLAINTS REVIEW
1. Complaints to CCDD and LEA
2. Complaints to Regulatory Agencies
3. Complaints to other Local Agencies
E. ISSUES RAISED'
1. Construction Issues
2. Operating Issues (Except Special Wastes)
- Page 2 -
Ii
I
3. Special Wastes Issues
a. Direct Haul of Non-transferable MSW
b. Direct Haul of Designated Wastes
C. Contaminated Soils as Proposed Cover
d. Proposed Disposal of Asbestos Waste
4. Haul Route Issues
5. Other Transfer/Direct Haul Issues
PART H
REVIEW CRITERIA FOR
COUNTY PLANNING COMMISSION
F. REVIEW CRITERIA FOR EXISTING CONDITIONS OF APPROVAL
1. Changes Required by New Regulations
2. Changes Required by Court Decisions
3. Correction of Demonstrated Significant Health Impacts
4. Correction of Demonstrated Significant Safety Impacts
5. Correction of Demonstrated Significant Public Welfare Impacts
RCZA:kcl-IW.rvw
6-13-95
- Page 3 -
City ®f Pittsburg
Civic Center • P.O. Box 1518 • Pittsburg,California 94565
� mom....,.......,
EE
OFFICE OF THE MAYOR .JUS! 2 0 1945
June 19, 1995 CLERK BOARD OF SUPERVISORs
CONTRA COSTA CO.
The Honorable Gayle Bishop, Chair
Contra Costa County Board of Supervisors
651 Pine Street
Martinez, California 94553
RE: AGENDA ITEM D.7: CRITERIA FOR REVIEW ON KELLER CANYON
LANDFILL LAND USE PERMIT (LUP 2020-89)
Dear Supervisor Bishop:
On June 5, 1995, we sent the attached letter to County staff requesting specific information
related to Keller Canyon Landfill, as well identifying specific issues that the City would like
to see addressed by the County Planning Commission when it considers the Landfill's LUP.
To date, we have not received any of the requested information. Furthermore, we just
received the Board Order for the subject agenda item today (by fax). We are somewhat
dismayed that our June 5th letter was not included as an attachment to the Board Order, and
we are particularly concerned that staff made no'effort to inform the Board of the issues the
City would like to have considered by the Planning Commission.
While the City has endeavored to work cooperatively, and in good faith with County staff on
this very important issue, these recent actions, or lack thereof, do not bode well for a new
cooperative working relationship between the City, County, and Keller Canyon Landfill
Company. In fact, staff's failure to respond to our information requests seems to be a
continuation of the County's improprieties related to Keller Canyon as identified by the
Contra Costa County Grand Jury in 1993-94.
Some of the issues that we may want addressed by the Planning Commission cannot be..,.
determined with certainty until we have had a chance to review the information that has been
requested, but not yet received. However, following is a partial list of issues (per our June 5th
letter) that we would like brought before the County Planning Commission:
A) We request the Planning Commission consider banning the receipt of all "special and
designated wastes at Keller Canyon Landfill regardless of whether the material is
generated by in-county or out-of-county sources.
California Healthy Cities Project
National Center for Public Productivity Exemplary Award - 1993
City of New Horizons
The Honorable Gayle Bishop; Letter
Agenda Item D.7
June 19, 1995
Page Two
B) If the Planning Commission does not find this desirable or appropriate, we would
appreciate the Commission considering a complete ban on the most dangerous of these
waste types; those which are currently defined by County staff as Category 4 and
Category 5 "special" wastes.
C) We request, prior to the Planning Commission Meeting, a research effort be
undertaken, and a task force convened to determine the potential contaminants and
toxins that may be present in the "special" and designated waste-types that Keller is
permitted to accept. The specific waste-types which should be analyzed include:
drilling muds; contaminated soils; shredder waste; commercial and industrial waste;
agricultural wastes; filter cake/dewatered sludge; construction/demolition debris;
geothermal wastes; cannery wastes; sewage sludge; and, spent catalyst fines.
D) Once the toxins and contaminants that may be present in the material-types discussed
above of have been identified, we request the Planning Commission require the that
each load of "special" and designated waste be tested for each of the toxins and
contaminants identified for that specific material-type.
Note: This may be withdrawn as a Planning Commission issue depending on our
receipt and review of the previously requested test data.
E) Likewise, once potential contaminants and toxins which may be present in the
material-types discussed above have been identified, we request that the LEA delineate
the allowable concentrations those contaminants that may be present in each material-
type landfilled at Keller, as indicated in applicable permits and regulations.
F) If warranted, based on the review of the last Health Risk Assessment performed for
Keller Canyon and an analysis of the information requested above, we will ask the
Planning Commission to mandate that a new Health Risk Assessment be performed.
Note: we have yet to receive a copy of the revised Health Risk Assessment (identified
in Keller's FEIR) as requested in our June 5th letter.
G) Finally, as requested by the City of Pittsburg and supported by the Contra Costa
Mayor's Conference last year, we request that the Planning Commission impose
conditions requiring each load of "special" and designated waste proposed for deposit
at Keller Canyon Landfill undergo a second, independent laboratory analysis. As
indicated in the attached newspaper clipping, Lab says it falsified pollution test results,
it is no unheard of for laboratories to falsify test results.
The Honorable Gayle Bishop; Letter
Agenda Item D.7
June 19, 1995
Page Three
We will appreciate these issues being incorporated into the outline of LUP-review criteria
prepared by staff, and placed before the Planning Commission for its consideration of Keller's
LUP.
We will also appreciate you facilitating the receipt of the previously requested information so
that we may consider what other issues may be appropriate for Planning Commission review.
While we understand that copies of test data for each load of "special" and/or designated
waste that has been received by Keller will be forthcoming per the Board's June 6th meeting,
as well as our information request, we are still very eager to receive a copy of Keller's
revised Health Risk Assessment (identified in the FEIR), as well as learn what the LEA has
determined to be allowable levels of each contaminant that may be found in each of the
special and designated wastes that Keller is permitted to receive.
Thank you very much for your ongoing cooperation and support in this matter.
Sincerely,
r
Taylor Davis
Mayor
cc: City Council
Michael Woods, Interim-City Manager/City Attorney
`•
0f Filia_sb�"_Erg
Civic Center • P.O. Box 1518 • Pittsburg, California 94565
OFFICE OF THE CITY MANAGER
June 5, 1995
Mr. Val Alexeeff, Director
Growth Management and Economic Development Agency
Contra Costa County.
651 Pine Street
Martinez, California 94554
RE: NON-MUNICIPAL SOLID WASTE RECEIPT AT KELLER CANYON
LANDFILL .,
The purpose of this memorandum is to request additional subject information and identify
issues that the City would like to see considered by the County Planning Commission when it
reviews Keller Canyon Landfill's Land Use Permit.
INFORMATION REQUESTS TO COUNTY STAFF
One of the actions taken by the Board of Supervisors at its May 1.6, 199.5,public hearing
regarding Keller Canyon Landfill's receipt of non-municipal solid waste (Agenda Item H.4)
was to direct staff to make available all records and corresponding test data for each load of
"special" and designated waste deposited at the Landfill.
We will appreciate receiving this information well in advance of the public workshops that
are anticipated to held on this subject. In gathering this information,please ensure that each
record clearly indicates:-'-) what tests were performed-, and, 2) which specific contaminants
were analyzed for in each test.
For example, as we identified in our May 23rd letter to Gayle Bishop (Attach-ment A), the
California Integrated Waste Management Board (CIWMB) has publicly acknowledged, in
LEA Advisory No. 5, that:
contaminants other than metals and petroleum hydrocarbons may occasionally
be present in "contaminated soils", depending on the source of the soil. Other
contaminants of concern include: solvents, pesticides, PCBs, dioxins/furans,
polynuclear aromatics, and soluble salts.
California Healthy Cities Project
National Center for Public Productivity Exemplary Award - 1993
F r.
City of New Horizons
-Val Alexeeff
Contra Costa County GMEDA
June 5, 1995
Page Two
Therefore, it would stand to reason that, in the case of contaminated soil being landfilled at
Keller, each load should be tested for, at least, levels of: metals, petroleum hydrocarbons,
PCBs, dioxins/furans, polynuclear aromatics, and soluble salts. If the test data for
contaminated soils does not indicate that each of these contaminants were indeed tested for,
there is obviously no way of determining whether or not they were present in the "special"
waste, or if the concentrations of these contaminants were below the levels allowed in Keller's
permits, or by regulation.
In the case of contaminated soil, the CIWMB's Suinniary Findings and Report For Sludge,
Ash, and Contaminated Soil: Appropriate Level of Regulatory Control Project (fourth draft,
April 1995) (Attachment B) specifically states that:
Used petroleum products, especially nonhazardous waste oils which accumulate
at gasoline service stations and automotive repair shops, frequently contain low
levels of lead, arsenic, chromium, and cadmium. [source cited: Energy and
Environmental Research Corporation, Guide to Oil Waste Management
Alternatives, pp. 413-415.]
Therefore, we would expect all test data for contaminated soil deposited at Keller (regardless
of the source of origin) to indicate that tests were performed to determine the presence of the
metals cited above (lead, arsenic, chromium, and cadmium), and if found, at what
concentrations.
TEST DATA REQUIREMENTS
If the test data that you provide regarding contaminated soil landfilled at Keller does not
indicate that all of the contaminants discussed above were tested for, please provide an
explanation as to why not. We understand that contamiriants that might be present in
contaminated soil may be dependant on the source of the soil, however any explanation as to
why a particular contaminant, or contaminants (identified above) were not tested for should
be supported by providiki-,g us with one of the following:
C,
1) Established guidelines, if they exist, delineating which tests should be performed
and which contaminants analyzed depending on the source of the contaminated soil;
or,
2) In the absence of 1) above, please provide the determination, as issued by the
appropriate regulatory agency, for each waste load landfilled at Keller, specifying
which tests were required, and which contaminants were required to be analyzed.
Val Alexeeff
Contra Costa County GMEDA
June 5, 1995
Page Three
LEA'S ROLE
Also, we would appreciate the County's Local Enforcement Agency delineating the
concentrations of the following contaminants (as may be present in contaminated soil) that
Keller is allowed to accept under its operating permits or regulation: petroleum hydrocarbons,
lead, arsenic, chromium, cadmium, solvents, pesticides, PCBs, dioxins/furans, polynuclear
aromatics, and soluble salts.
We realize that allowable thresholds for these contaminants may be established through
permits other than the Landfill's Solid Waste Facility Permit, and determined initially by
agencies other than the LEA. However, the CIWMB's LEA Advisory No. 5 clearly states that:
If present, the LEA should monitor records at the facility to ensure that such
contaminants are below levels required by regulations or permits.
Since the LEA has already indicated that such records are present, we assume that they are
familiar with allowable levels for each contaminant. In our mind, failure to provide this
information will be a clear indication that the LEA has not carried out its responsible to
ensure the health and safety of the communities surrounding Keller Canyon.
In addition, please send us the final copy of the Health Risk Assessment referenced in the
Final Environmental Impact Report for Keller Canyon Landfill. Being able to review this
document will allow an evaluation of whether the Health Risk Assessment is consistent with
the levels, of "special" and designated wastes now allowed to be disposed of at Keller, or
whether preparation of a new Health Risk Assessment is warranted. Please be advised that v,,e
consider receipt of this document critical the forthcoming Planning Commission review of the
LUP.
SUMMARY OF REQUESTED INFORMATION
We believe the information requested above is straight forward should not require a great deal
of explanation due to its technical nature. To avoid any confusion in the response, a summary
of our requests follows:
1) Provide test data for each for each load of "special" and designated waste that Keller
Canyon Landfill has received. Please ensure that this data clearly indicates which tests
were performed, and which potential contaminants were tested for, in addition to
providing, all test results,
Val Alexeeff
Contra Costa County GMEDA
June 5, 1995
Page Four
2) In the case of contaminated soil landfilled at the facility, please ensure that all
test data indicates the information requested in 1) above, as well clearly
indicates whether tests were performed to determine the presence of petroleum
hydrocarbons, lead, arsenic, chromium, cadmium, solvents, pesticides, PCBs,
dioxins/furans, polynuclear aromatics, and soluble salts, and what
concentrations of these compounds were identified.
If tests performed on contaminated soil did not analyze each of the contaminants listed
above, please explain as to why not by providing a copy of established guidelines as
to which testing is required for contaminated soil originating from particular sources,
or a case by case demonstration of which tests were required by the appropriate
regulatory agency.
3) Please have the LEA identify the allowable levels of petroleum hydrocarbons, lead,
arsenic, chromium, cadmium, solvents, pesticides, PCBs, dioxins/furans, polynuclear
aromatics, and soluble salts that may be present in contaminated soil landfilled at
Keller, as identified in the Landfill's permits, or in regulations.
4) Please provide a copy of the final Health Risk Assessment referenced in the Final
Keller EIR.
ISSUES FOR COUNTY PLANNING COMMISSION CONSIDERATION
When the County Planning Commission convenes to review the Keller Canyon LUP, we will
appreciate the following items be included for consideration:
A) As previously stated, we request the Planning Commission consider banning the
receipt of all "special" and designated wastes at Keller Canyon Landfill regardless of
whether the material is generated by in-county or out-of-county sources.
B) If the Planning commission does not find this desirable or appropriate, we would
appreciate the Commission considering a complete ban on the most dangerous of these
waste types; those which are currently defined by County staff as Category 4 and
Category 5 "special" wastes.
Although we have,been able to determine the contaminants and toxins that may potentially be
found in contaminated soils, identifying contaminants and toxins that may be present in the
other "special" and designated waste types that Keller is permitted to receive is not as clear.
For example, a brief review of the CIWMB's Sionniar), Findings and Report For Sludge, Ash,
and Containinated Soil: Appropriate Level of Regulatory Control Project (fourth draft, April
1995), indicates that contaminants and toxins that may be found in sewage sludge[biosolids
Val Alexeeff
Contra Costa County GMEDA
June 5, 1995
Page Five
will vary depending on the treatment plant's influent, as well as treatment processes, but can
include heavy metals (including arsenic, chromium, and nickel), pathogenic organisms,
hazardous materials, cyanides, oil and grease, and other pathogens.
C) We request, prior to the Planning Commission Meeting, a research effort be
undertaken, and a task force convened to determine the potential contaminants and
toxins that may be present in the "special" and designated waste-types that Keller is
permitted to accept. The specific waste-types which should be analyzed include:
drilling muds;_contaminated soils; shredder waste; commercial and industrial waste;
agricultural wastes; filter cake/dewatered sludge; construction/demolition debris;
geothermal wastes; cannery wastes; sewage sludge; and, spent catalyst fines.
D) Once the toxins and contaminants that may be present in the material-types discussed
above of have been identified, we request the Planning Commission require the that
each load of "special" and designated waste be tested for each of the toxins and
contaminants identified for that specific material-type.
E) Likewise, once potential contaminants and toxins which may be present in the
rnaterial-types discussed above have been identified, we request that the LEA delineate
the allowable concentrations those contaminants that may be present in each material-
type landfilled at Keller, as indicated in applicable permits and regulations.
F) If warranted, based on the review of the last Health Risk Assessment performed for
Keller Canyon and an analysis of the information requested above, we will ask the
Planning Commission to mandate a new Health Risk Assessment be performed.
G) Finally, as requested by the City of Pittsburg and supported by the Contra Costa
Mayor's Conference last year, we request that the Planning Commission impose
conditions requiring each load of "special" and designated waste proposed for deposit
at Keller Canyon Landfill undergo a second, independent laboratory analysis. As
indicated in the ---ached newspaper clipping, Lab says it falsified pollution test results,
it is no unheard of for laboratories to falsify test results (Attachment Q.
Val Alexeeff
Contra Costa County GMEDA
June 5, 1.995
Page Six
Thank you for your cooperation and prompt attention to these requests. We believe that the
information being requested is necessary to fully participate in the anticipated workshops and
Planning Commission meetings on this subject.
If you have any questions related to the information requests or Planning Commission issues
discussed above, please contact me at 439-4850.
Sincerely,
Yolanda Lopez
Assistant City Manager
attachments (3) A. May 23, 1995 Taylor Davis letter to Gayle Bishop
B. "Summary Finding and Report For Sludge, Ash, etc."
C. May 3, 1995 Contra Costa Times article
"Lab says it falsified pollution tests results"
cc: Dan Guerra, Deputy Director Environmental Health Division
Wednesday, May 3, 1995 Contra Costa Times-7D
Sacramento County
1.4b says it falsified ,.
Pollution tests.'results
SACRAMENTO An environ-
mental laboratory said it falsified the
re$ots of government-commissioned
pollution-tests at hazardous waste
sites around the county,
Eureka Laboratory's lawyers
made the admission during a trial in
federal court of the company and
two,of its Iormer employees.The at
torneys on Monday informed U.&
Di'frict Judge Edward I Garcia that
the company wished to plead guilty:
`Attorney.Woon Ki Lau of Denver,
with company president Steven Le-
'ung, admitted that Eureka used so-
phisticated computer.software corn
mands to concoct.analytical test
results to make it;appear the labo-
ratory's equipment was properly cal-
ibrated and.maintained:
The case:wiped out data from
hundreds water and soil tests sup-
plied the U.S..Environmental Pro-
tection Agency.The data's integrity
was vital to the`identification and
cleaiiup.of;hazardous,substances at
various Siperfund sites that quali-
fied for fuzi&allocated for the most.
aggravated locations.
TO' BOARD OF SUPERVISORS � Contra
FROM: MARK FIlI3UCANE, HEALTH SMVICM DIRECZ RCO t
O:
County
� 4
.'V
DATE: JANE 20, 1995 `�; ::..��.:..��
SUBJECT: Xe ler Canym Waste Disposal Issues
SPECIFIC REOUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
BACKGROUND:
The attached report is being submitted as directed by the Board of Supervisors in response to
questions and issues raised concerning Keller Canyon Landfill waste disposal issues.
RECOMMENDATION:
Accept the report from the Health Services Department, Environmental Health Division,
regarding Keller Canyon Landfill waste disposal issues.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATUREM: --
ACTION OF BOARD ON APPROVED AS RECOMMENDED OTHER
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
UNANIMOUS(ABSENT _._ AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN.
Contact: Daniel Guerra, Deputy Director, Environmental Health
CC: Dr. William Walker ATTESTED
Val Alexeeff, 24MA PHIL BATCHELOR,CLERK OF THE BOARD OF
Rebecca Ng, Environmental Health SUPERVISORS AND COUNTY ADMINISTRATOR
Keller Canyon Landfill Inc.
BY DEPUTY
Contra Costa County
the Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR
Tom Powers, 1st District Mark Finucane, Director
Nancy C. Fanden, 2nd District se t
Robert I. Schroder, 3rd District
/-, �,�-:_•. 20 Allen Street
Sunne Wright McPeak, 4th District r - ` Martinez, California 94553-3191
Tom Torlakson, 5th District
(510) 370-5003
County Administrator xe,- �' ' A.oe (510) 370-5098 Fax
`4
Phil Batchelor `Osi---`-
County Administrator
DATE: June 20, 1995
TO: Board of Supervisors
FROM: Mark Finucane, Health Services Director ffr4;r�
SUBJECT: Keller Canyon Landfill Waste Disposal Issues
The Board of Supervisors directed the Health Services Department to report on a number of
issues that arose regarding Keller Canyon Landfill during the hearing of June 6, 1995. This
report addresses those issues.
Public Access to Laboratory Analyses
The LEA was directed to obtain the laboratory analyses from Keller Canyon Landfill and
recommend an appropriate location for the public to access the analyses. Health Services has
secured the first floor at 1111 Ward Street to temporarily store the analytical data and make
them available to the public. Interested parties must request access at the Environmental Health
Division office on the third floor of 1111 Ward Street. Staff will accompany the party to the
first floor and oversee the record review. Copies of any data will be provided and charged for
as are all public records.
Air Quality Studies
Supervisor Rogers cited a study that was conducted in various cities concluding that dust may
reduce life expectancy. Staff was requested to obtain a copy of the newspaper article. Staff
contacted the Bay Area Air Quality Management District (BAAQMD) and the West County
Times. BAAQMD and the Times were unable to identify or provide a copy of the article cited
by Supervisor Rogers.
The BAAQMD engineer said it is known that when emissions in the air are breathed in, they
affect the public health. Many studies are being conducted throughout the country on the various
issues of dust such as particle size, how they affect health, etc. Dependent on the findings,
regulations may be changed to be more restrictive.
Supervisor Rogers also requested copies of any studies conducted on the air quality at Keller
Canyon Landfill. Studies were conducted on the Keller Canyon site prior to siting the landfill
for compliance to the California Environmental Quality Act (CEQA). A copy of the findings,
mitigation measures, and comments are attached for your review in Attachment A.
Merrithew Memorial Hospital& Clinics Public Health • Mental Health Substance Abuse Environmental Health
• IContra Costa Health Plan Emergency Medical Services Home Health Agency Geriatrics
r•
.Board of Supervisors
Report on Keller Canyon Landfill Waste Disposal Issues
June 20, 1995
Page 2
Record Correction
Two issues were raised during the public hearing segment of the Keller Canyon Landfill agenda
item on June 6, 1995. The information given by Frank Aiello and Mary Erbez may be incorrect
and misleading.
1. Ms. Erbez stated that the construction of the liner and provision of the leachate collection
system was specifically required of Keller Canyon Landfill because of the proximity to
groundwater.
At the time of design of Keller Canyon Landfill, the industry and regulatory community
consensus was that a composite liner composed of a clay layer and a synthetic geotextile
material was far superior to the single liner specified in Title 23, Chapter 15 of the
California Code of Regulations. Additionally, it was anticipated that Subtitle D of the
Code of Federal Regulations was going to require composite liners and leachate
collection systems for all new landfills and expansions of landfill. Therefore, the design
of all new landfills was required to provide composite liners and leachate collection
systems by the regulatory agencies.
Consequently, Phase I of Keller Canyon Landfill with a composite liner and leachate
collection was completed and opened for waste receipt in May 1992. Subtitle D with
these two requirements became effective on October 9, 1993.
2. Mr. Aiello asserted that the LEA violated Section 17258.29 of Title 14, California Code
of Regulations (CCR) by not providing him and Citizens United with the analytical data
on waste received at Keller Canyon Landfill.
Attachment B, C, and D, are copies of Section 17258.29 and Section 17639 of Title 14,
CCR, and a letter to Citizens United regarding the provision of operating records.
Section 17258.29 states: "The owner or operator of a municipal solid waste landfill unit
must record and retain near the facility in an operating record or in an alternative
location approved by the California Integrated Waste Management Board the following
information... testing or analytical data...". Additionally, Section 17639 requires that
the records shall be open to inspection by authorized representatives of the Enforcement
Agency during normal business hours. The regulations do not require that the
enforcement agency acquire operating records to make them available for the public.
The attached April 6, 1994 letter is the LEA response to Citizens United's request for
operating records. The letter specifies what records are available and the assertion that
the LEA is not required to obtain operating records on Citizens United's behalf.
Should you have any questions, please contact Rebecca Ng at 646-1251.
Attachments BN2:bos6.20
AIR QUALITY
Environmental Setting
Climatic Setting
wo The proposed Keller Canyon Landfill project is located in the San
Francisco Bay Area Air Basin (SFBAAB), near the western end of the San
Joaquin/Sacramento River delta, south of Pittsburg. Main features of the
air basin are the coastal and inland mountains (with elevations up to
1,500 feet), valleys, and bays. A persistent high pressure system over
the eastern Pacific Ocean contributes to the general summertime pattern
in the air basin of daytime northwesterly and nighttime southerly winds.
Except for frequent coastal fog, summers tend to be relatively warm and
dry. In the winter, the high pressure system moves to the south, and
® winter storms frequently produce precipitation over the area. Inland
■■� valleys often experience wintertime fog (BAAQMD 1985) .
Keller Canyon itself is in an area that is characterized by rolling
hills (with elevations up to 1,000 feet) and their adjacent valleys, and
by the Suisun Bay to the northwest. The surrounding terrain has a
definite effect on the air flow patterns around the proposed landfill
site, as the winds tend to be channelled along the valleys. In the
Pittsburg area during the summer months, predominant winds are from the
west and average 14.4 miles per hour. Winter winds are predominantly
southeasterly (5.8 miles per hour, average) and southwesterly (7.7 miles
per hour, average). On an annual basis, the winds are - predominantly
westerly, averaging 12.3 miles per hour. Wind conditions in the Keller
Canyon area are highly variable, especially in the winter, as they are
Ndependent on many factors within the basin, including air flow from the
San Francisco Bay and inland surface heating and cooling. The surface
1Ztemperature changes cause upslope and downslope wind which may differ
from the regional wind patterns. Three wind monitoring stations were
placed at the Keller Canyon site by CH2M Hill in March 1989; data for
velocity and wind direction at the landfill berm site indicate generally
southwesterly winds from March 9 to May 25 and July 6 to July 20. Winds
averaged approximately 10 miles per hour with gusts sometimes greater
3-111
136-03.R9 10/26/69
than 2 m les per hour. At a monitoring station in a swale approximately
one-hal ile north of the northern end of the landfill footprint, the
predominant wind direction from July 6 to July 20 was south-southwest,
with speeds of 17 miles per hour and higher approximately 50 percent of
the time monitored. (Additional wind data are currently being collected
by CH2M Hill .)
Temperatures in Pittsburg range from an average summer maximum of
87.8°F and an average winter minimum of 38.7oF, with an annual average of
62.20F. Average summer and win ter *temperatures are 75.70F and 48.50F,
respectively (NOAA 1982) .
Most of the precipitation in the area falls during the winter
months, for an average annual rainfall in Pittsburg of 14.4 inches.
Generally, 89 percent of the precipitation falls from November through
April , and 68 percent from December through March (NOAA 1982).
Normally, atmospheric temperatures decrease with altitude although
temperature inversions are common in the SFBAAB. An "inversion layer",
which is a layer of warm air above a layer of cool air, limits vertical
air mixing and dispersion, which effectively trap pollutants. Summer
inversions are typically 1,000 to 2,000 feet above sea level , and are
caused by downward air motion which compresses and heats the air.
Typical winter inversions tend to form near the ground, as they are
caused when air cools at night in contact with the cold ground surface.
Either type of inversion may take place during any season. In the autumn
months they generally combine, which may lead to even poorer vertical
mixing, especially in the inland valleys (BAAQMD 1985) .
Wsting Air Quality
To protect the public health, safety, and welfare, both National
Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality
Standards have been established. These standards allow for a "margin of
safety", above which health and safety risks are known to exist,
especially with long-term exposure. The California Air Resources Board
(CARB) compiles air quality data from monitoring stations throughout the
state. Bay Area Air Quality Management District (BAAQMD) operates most
3-112
136-03.89 10/26/89
i
of the monitors within the air bilin, and also ,compiles and interprets
data from the monitoring network.
There is a CARB monitoring station located at 583 10th Street in
Pittsburg. This station collects data on ambient levels of ozone (03),
carbon monoxide (CO), nitrogen dioxide (Nod, sulfur dioxide (SO2), and
total suspended particulates (TSP) . Data on particulate matter smaller
than ten microns (PMIo) is not collected in Pittsburg; therefore, these
values were obtained from the station in nearby Concord. Data collected
from these sites would be representative of the existing air quality in
the proposed project area. Table 3.14 presents the maximum concentration
from these pollutants for the averaging time given, and also the number
of days the state and federal standards were exceeded.
Of the monitored pollutants, only ozone levels at the Pittsburg
station exceeded both the California and federal standards. At the
Concord station, PMIo levels for 24-hours exceeded the California
standard of 50 micrograms per cubic meter (µg/m3) but not the federal
standard (150 µg/m3) .
Ozone is considered to be the main constituent of smog. Complex
photochemical reactions between reactive organic gases (ROG) and nitrogen
oxides (NOx) in the presence of sunlight result in smog. Sources of ROG
in the proposed project area are motor vehicles, fossil fuel combustion,
organic solvents, the petroleum industry; and power plants. Effects of
ozone include aggravation of respiratory diseases, vegetation damage,
visibility reduction, and eye irritation. Ozone itself is colorless and
pungent.
Particulate matter may be made up of several types of fine solid or
liquid particles, including dust, smoke, ash, mist, and fumes. Sources
include combustion of fuels, agricultural practices, construction
ILA
activities, road dust, industrial processes, along with natural sources
of sea spray, forest fire smoke, volcanic eruptions, and wind-blown dust.
Particulates cause and aggravate respiratory diseases and severely limit
visibility.
1W
N 3-113
136-03.R9 10/26/89
M
to
•-+ 0 Ll9 O.-r
O CNL1") O 1 AO 1 00 LAA
M + i {1t tt9 LC1 ty
N c
C c
m
V) Co Ln Ln Ln
Q Q �'+ Cl CV O N !^
4�
O C?tiA 1 O + OA 00 + + C
N 1 : 1 en Ltf i i 0
�o
v
ON .-+CO LA
N r-+M 0 A A
W •"+ AA O�-+ OAO Lri O T
La O O CO GQ 00 000 Oto +IT CTI
Lam NCO to N C
Q O � N
W-R
{If
wr}'o AA AA AAA A -it A0
� d
O ro n
N
29 CD
Ct CC O L
CC CAO
cz
S +� 0) .-+CO v~i
C Lr) .-r co O O M
4a) x) Pts ; Lr) A O C) O O A •-+C? m % c
Q= C Oct O Lt90J AO AAO to L[) Nt0 p
N CO 40 at
,..t
aN
w
..I H 106 43 N c O
co
C O
O >~ OA OO OO Ot0-r AO C c
CO .�
sm � 2: Q Vco
t0
H ~ •�-`
a E
E
A X
LL. Q b o
co mt
YC O O �^+CN O A-Wco x 0 t 00 000 OO
o � A
t/1 ti
.'E O CT Ln 00 000 M*%D* •-+ N W >
>. i N C0 Ln A t
C1. 0 co .� C x sl
CN Y +v to �o
W -4 CA
A M
C > +
Cl a ys �+ O A A CD 0 A 0 C) -r& 0 0 x
cc Z
ro e > °
a
Z:ui Q G La V +'
d
CD
3r. 3C
b E L. L i r— L r O S. r O r O �s c :+ o
L r O O O ro O ro O O ro 0 - ro O 1,. �+ •o t_ H
+
N Q N q p L d
ve n € m
e
S
O CD G a O m O CL �� a. --- L v a L v f 1
r- Cl C1 Z" d N d $ o T .0 A
0.
'� = N fn i
Although Pittsburg values for carbon monoxide were below state and
federal standards, other areas within the basin are non-attainment for
carbon monoxide. Carbon monoxide is a product of incomplete combustion
of fossil fuels. Motor vehicles contribute approximately 85 percent to
the total CO emissions in California. Other sources are industrial fuel
combustion, forest fires. and open burning.
Because the project could impact ambient carbon monoxide (CO) con-
centrations by creating increased automobile exhaust emissions, CALINE4
dispersion modeling was performed to determine existing CO levels.
Using existing traffic volumes and emission factors given by BAAQMD
(1985), emissions were calculated for PM peak hour traffic. Traffic was
assumed to be traveling five miles per hour below the posted speed limit.
The model was run using assumed worst-case meteorology which included a
low wind speed (0.5 meters/second) and very stable conditions. The wind
directions were varied about the compass at ten-degree increments, for a
total of 36 wind directions for which short-term (one-hour) CO
concentrations were calculated. Background CO concentration was set at
zero. For modeling purposes, 20 theoretical receptors were placed along
major roadways, near the project area, and at sensitive receptors.
Sensitive receptors are schools, hospitals, and nursing homes. Parks
along major roadways are also considered sensitive receptors. There are
ten sensitive receptors in the project area.
Results of the modeling for existing conditions are given in Table
3.15 and show that neither the California nor the federal CO standards
are being violated. The eight-hour impacts were assumed to equal 70
percent of the one-hour impacts (Midurski 1978) .
Air Oua7itY Reau7ations
The Bay Area Air Quality Management District (BAAQMD) is
responsible for regulating the emissions within the project area. The
proposed project must be consistent with the 1982 Bay Area Air Quality
Management Plan.
3-115
136-03.R9 10/26/89
t
TABLE 3.15
MAXIMUM BACKGROUND CO CONCENTRATIONS
IN THE KELLER CANYON AREA
Standards
Averaging Maximum Impact California Federal
Period ppm ppm ppm
One-Hour 6.0 20 35
Eight Hour 4.2 9 9
Because the air basin is a non-attainment area for ozone, primary
efforts of the BAAQMD point toward reduction of hydrocarbon emissions.
Although the Bay Area has had large reductions in air pollution resulting
in cleaner air since 1969 (ozone has been reduced by 60 percent) it is
expected that this trend will be overwhelmed by increased population
growth and development in the area. Particular emphasis is being placed
on reducing pollutants which contribute directly to the PM10 levels or
those which are precursors to ozone development.
The regulations to which the proposed landfill is subject fall into
three general areas: New Source Review (NSR) , Prevention of Significant
Deterioration (PSD), and Prohibitory. PSD and NSR rules are very similar
and are often written into a single regulation. Regulation 2, Rule 2 of
the BAAQMD Rules and Regulations requires that any facility that emits
criteria and/or non-criteria pollutants at a rate that exceeds specified
thresholds must use the Best Available Control. Technology (BACT) . to .
reduce emissions. BACT requirements apply only to stationary sources- and
not to emissions from mobile equipment such as bulldozers, scrapers,
water trucks, and haul trucks. Emission offsets (i.e., reductions in
emission from existing sources) are required by BAAQMD for emissions of
non-attainment pollutants (organics and NOX) that exceed specified
thresholds. In addition, BAAQMD administers PSD review for new sources
that emit criteria pollutants for which the area is currently designated
attainment. Exceedance of a PSD trigger level requires a demonstration
by modeling that the emissions will not interfere with the attainment or
3-116
136-03.89 10/26/89
maintenance of any federal ambient air quality standard at the point of
maximum impact and will not cause an exceedance of a PSD increment.
® In addition to the permit requirements of Regulation 2 established
by the BAAQMD, the proposed facility operations must comply with a number
of prohibitive restrictions. These include limitations on particulate
matter and visible emissions, organic compounds. inorganic gaseous
pollutants, and hazardous pollutants. Regulation 8, Rule 34 sets limits
of organic compound emissions at landfills and requires landfill
operators to collect landfill gases through a gas collection system.
BAAQMD Regulations 7-101 and 102 limit emissions from odorous substances
if the odors are perceived at or beyond the property line.
Existing Landfill Air Quality Studies
Landfill Gas
Landfill gas (LFG) , which consists primarily of carbon dioxide
(CO2) and methane (CH4) , is produced by the anaerobic decomposition of
solid wastes in landfills. Evaporation of hazardous materials (those
materials that are corrosive, reactive, flammable, toxic, or infectious)
that have been deposited in municipal landfills also contributes to the
® formation of varying compositions of LFG.
Table 3.16 presents the typical composition of landfill gas samples
collected in a non-hazardous landfill . Trace constituents make up a
small percentage of the gas, but these compounds generally are toxic and
could present health risks to the public, according to the California
Waste Management Board (CWMB) . These gases could also be harmful to
animals, plants, and the environment.
3-117
136-03.R9 10/26/89
i
TABLE 3.16
TYPICAL CONSTITUENTS FOUND IN LANDFILL GAS SAMPLES
Percent
Component (Dry Volume Weight)
Methane 45 - 60
Carbon dioxide 40 - 60
Nitrogen 2 - 5
Oxygen 0.1 - 1.0
Sulfides, disulfides, mercaptans, etc. 0 - 1.0
Hydrogen 0 - 0.2
Carbon monoxide 0 - 0.2
Trace constituents 0.01 - 0.6
Source: Department of Civil Engineering, University of California, Davis.
Trace Constituents in Landfill Gas. 1981.
Twenty-six of these trace constituents have been classified as
"primary toxic pollutants" by the Environmental Protection Agency (EPA) .
They are (common names):
1,1,2-trichloroethane ethylenedichloride
1,2-dichloroethylene ethylidenechloride
1,3-dichloropropylene methylbenzene
2,3-dichloropropylene methylchloroform
acetylenedichloride methylenechloride
benzene orthodichlorobenzene
bromoform perchloroethylene
carbon tetrachloride phenylchloride
chloroform phenylethane
dibromochloromethane tetrachloroethane
dichlorobromomethane trichloroethylene
1,2-dichloropropane vinyl chloride
ethylenedibromide vinylidene chloride -
Several California laws require testing of LFG and ambient air at
municipal solid waste disposal sites (AB 3525, AB 3374, California Health
and Safety Code section 41805.5, and California Government Code section
66796.54). Following guidelines outlined by the State of California Air
Resources Board (CARB) and the California Air Pollution Control Officers
Association (CAPCOA), testing for ten of the trace constituents has taken
place at existing landfills since 1986. These guidelines were formulated
to provide a "screening of potential health impacts of disposal sites"
(CARB 1989) . The ten contaminants selected by CAPCOA with the assistance
3-118
136-03.R9 10/26/89
i
of the California Department of Health Services (DHS) have known health
effects associated with long-term exposure, especially carcinogenicity
(CARE 1989) . These contaminants, their classifications, and the agency
making the classification are presented in Table 3.17.
Various kinds of tests were done at landfill sites, including: (1)
integrated surface sampling immediately above the surface of the
landfill ; (2) gas sampling from five wells within the landfill ; (3)
ambient air samples taken downwind and upwind of the sites; and (4) gas
migration testing.
A summary of test results of 326 non-hazardous and 30 hazardous
waste sites was presented to the California Legislature in June 1989, by
the CARB Stationary Source Division. Some of these landfills were
installed without the newly required landfill liners and without LFG
collection and disposal (e.g. flaring) systems. Analysis of the data
collected from the testing led the CARB staff to these preliminary
conclusions:
• Specific contaminants selected as indicators of hazardous waste
are present in approximately 306 of the landfills tested,
regardless of whether the site accepted hazardous or non-
hazardous waste. In the remainder of the landfills tested,
there was no indication of hazardous waste in the landfill gas
• Hazardous and non-hazardous waste sites appear to be similar in
their ability to produce toxic gases.. Approximately 60 non-
hazardous sites had higher peak concentrations 'within . the
landfill of one or more of the ten specified contaminants than
hazardous waste sites
• In some cases, toxic gases escape from landfills and disperse
into the ambient air. These gases can degrade air quality
• Methane at concentrations exceeding five percent (the standard
in 40 CFR 258.23 (a)(2)) was found to be migrating off-site
underground at approximately 20 percent of the sites
3-119
136-03.R9 10/26/89
c.0 C
r H Q
to r�
Owry' &n Q O O
C> iV M tV
'~ ul
� t .•.t t
i J at t
N t N
at tat h to N Q O
u +- 4.)
C cn L
tJ F- d
♦.r
C tY
4z U
C
C" •r t7�t:Qd �QQQ �QQQ *-+QQd dQd Qdd
a E W =40. dt]. 0.0. =0. 0. 0. t>0. 0. 0. 0. a. 0. 0. 0. 0.
mwa �••�WW ttrWWW —WWW ZWWW WWW WWW
Q " to
w to
C] A
to
w
C C C C C C
ro ro ro ro ro A
N r a �-- a '-- a
W r u +•- u r u �- r- r-
v> C o c o c a c o a o
¢ Q v 0. ro 0. A 0. A Cl. a. 0.
to a +j •61 a v a a a
t•. +•t W u 0 41 u to +) Vto *.� u 4.ju +t u
J u ro x a ro x O ro X O t0 X ro x A X
M tr r v 3 0 N M O (A 3c O t/)3 0 :3c a 3 0
L. W C F- C F- C F- C I-- C F- C F-
W a N a N H a 0 0 a 0 to a VS a H
J S N 01 7 >1 iT O Q >s Ct> C >.) M = 7 !t 0) O >.I
m ¢ to Q o+s 0 0 0 0004.) 0 0 04J Q o +s a a ++
¢ J ro C'O C"0'0 '- C L7'L7 +� C T3 Z7 r C•p•r- C� •'-
}� r- •+- i i v- L L S-
u
u ro 0 u ro ro a u A ro 0 u A A 0 u ro O u A 0
L i L N i _
�••� N z N 1V•r- N •�- N N •r i N L N •-
>+C A A L A A A L A A A I ro ro A i A A L ro A L
0120. tJZ20. tu2S0. t..>S20. tJ20. fust]
CP c a
A A C
E tat E O
ro a E a a i
tJ
O
CA-
acs v .0
to
r- c cv cw u .t-s
� a +• r a
to
_u
E
a
cc
CD
.c a
E O r a
O
u a c c a a
r-
c c � .rc L to 1
m L" w a
t
•c«� cO
Her•
Ln N
04- ,
.tet et M M
tv tv L + + + +
L J CU N &n %O Go �
^E 8
CU W N'! CS .) CD is C
U 41 r
V rCL o i
Q
O V C c
�•r Z
� C ro
n, 4- Q CL CL Ci a. a Q Cl Ci CL ¢c. c..Ci
Q,tU•.- .--+W W W W W +-- W W W .-•W W W v c a,
N
G to ; L
� m c o a
L O H
p L i
C1. 4 d
� N �
4
N
C C C C
ro ro ro ro a ++ u
ff,
W
O C C O O C O C O
C O to CL C- ro CL tor 0 a LS. L c
•t4-J,.r •r � O Q1 +� CU � CU -.� -
4J +s +A U �.: U H U H +-+ U rnc CL
ro N •r N •r ,� h+r .A N•r Off, +dr, .c
O U O ro X ro X O ro X O ro X d +,
i.7 •«- N3 O O to3 0 N3 O aV
... v- r r C r C r a L
r Qi N 4A N w N CA Q3 N N
41 O +•+ O O O •N 0 0 O +j
W L • ' n
C4
u h qw U ro IV O 4v O 0 L0 XE
N N
.i ro ro ro L ro L ro ro ro L tvm w L d y 0 N L
Q C�S2CL SCl. CwSSCS L)SSO• y 4+ °' e O
q tr
ro d ^ C r V H N
C h +0
ro CU d U Co t N U
t O CU C �j
E CU �} _ ' U L ��� d 4
0 S " z
S p d E i m co v `s .�• "
W p •r O O h +C C °
r a v a x c io a
+ r e•- c v �+ q L e[ x - r-
0
w
y c m 4 c
v r L
CL
• }O. .-+ r r aci c
r
ro { •.n 4 6. O+ Q M V Y C
' O u C ^ C d C C C
c do
O V h D+
6 n. o s c a
U O C C r iu. L 10 i
CP u
c WNI r +a
C
O + O 41 € cr +2d '• G, O T , x c o
O '_ p a• arc w w u� c .+ c s �-oIm
+�
L1 C U C 4 d C L N N O
L •M •'- r10
-
Cro> S r W a 4A4 u
_ i
Household hazardous waste is currently commonly disposed of in
municipal landfills. Although disposal of hazardous materials is not
permitted, household generators are not regulated, and detection of small
amounts of household hazardous materials is difficult. Programs to
intercept household hazardous materials are needed to intercept these
wastes and afford appropriate disposal . The California Waste Management
Board states that it is probable that all municipal landfills receive
some "volatile toxic wastes", and therefore there is potential for the
emission of these wastes into the atmosphere. Along with decomposition
and evaporation of wastes, chemical reactions between wastes that
generate gases are common processes by which hazardous wastes infiltrate
landfill gas.
The potential effects of these wastes on ambient air quality are
summarized by CARE in its report to the legislature:
• Toxic chemicals escape through the cover of sanitary landfill
and disperse into the ambient air. This escape and migration is
dependent on the type of waste, temperature, moisture content of
waste and cover, composition and depth of the cover, and other
factors.
• Although the ten specified contaminants found in LFG and the
surrounding ambient air are known to cause acute and/or chronic
health effects, CARE notes that the testing to date has not yet
been extensive enough to determine the increase in health risks
due to exposure to LFG.
• Ambient air quality standards, especially for ozone and vinyl
chloride, may be exceeded in the vicinity of landfills due to
emission of LFG. Illegal disposal and the natural process of
the breaking down of solvents by bacteria both contribute to the
presence of vinyl chloride in a landfill . Nitrogen oxides from
various sources react with hydrocarbon emissions from landfills
to form ozone, which is the primary constituent of smog.
• Global warming, or the "greenhouse effect", is caused by the
accumulation of certain inert gases in the atmosphere, which
3-122
I35-03.89 10/25/89
i
absorbs and effectively traps radiation. (heat). Carbon dioxide
and methane, main components of LFG, are important greenhouse
gases. Flaring or incineration of LFG also emits carbon
dioxide. CARB concludes that LFG (or the incineration of LFG)
may be a contributing factor in global warming.
Regulations and Requirements for Landfills Pertaining to Air
ualit
In 1984, California adopted a new classification system for
landfills. Class I landfills will accept hazardous waste, Class II sites
are for designated waste, and Class III landfills are for municipal solid
waste. The proposed Keller Canyon Landfill has been specified as a Class
II site, which means it would accept wastes that are non-hazardous, but
these wastes may release constituents in concentrations that are in
excess of applicable water quality objectives (CWMB 1987) .
The Bay Area Air Quality Management. District (BAAQMD) has
jurisdiction over the regulation of emissions from the proposed landfill .
Owners/operators of landfills, by Regulation 8, Rule 34 of the Bay Area
Air Quality Plan (BAAQP), are required to collect landfill gas in a
system approved by the District Air Pollution Control Officer (APCO) .
LFG must then be processed to "reduce the amount of organic compounds in
collected gases by at least 90 percent by weight". Rule 34 states that
this will be accomplished by either "burning the gases in a flare or
internal combustion engine approved by the APCO, or by processing the
gases by a control device or facility" approved by the APCO.. An
Authority to Construct and Permit to Operate must be received from BAAQMD
for the flare.
BAAQMD also addresses the issue of land use conflicts resulting
from new industrial sources (including landfills) when the proposed site
is near sensitive receptors (housing, schools, parks, etc.). The
District remarks that future industrial development should take into
consideration the proximity of sensitive receptors.
Landfill emissions that are odorous may be subject to BAAQMD's
Regulations 7-101 and 102, which limit emissions from odorous substances
3-123
136-03.R9 10/26/89
t
if the odors are perceived at or beyond the property line. There are no
standards for odors, which are regulated as a nuisance, based on
complaints. BAAQMD enforcement and engineering staff have identified
Class II and III landfills as highly potential causes of odor/nuisance
complaints and litigation due to garbage odors and dust, especially if
sensitive receptors are nearby or downwind from the landfill . BAAQMD
recommends that although difficult to quantify, potential odors from a
landfill should be considered when planning new projects, along with the
application of sufficient mitigation measures.
Impacts and Mitigation Measures
Impact I - Traffic-Ori9fnated Air Quality Impacts
The traffic volumes for the project were added to the existing
traffic volumes to estimate the total effect of the project. Automobile
traffic generates CO, HC, NO,, TSP and SO,,. Carbon monoxide is generated
in the largest quantities. BAAQMD recommends the use of dispersion
modeling to predict the worst-case ambient CO concentrations which would
result from the emissions of motor vehicle traffic. The CALINE4 model ,
used to estimate existing conditions, was again used with the same
parameters to calculate the CO concentrations. An average speed of 25
mph was assumed for vehicles, including transfer trucks (speeds may be
somewhat lower for loaded trucks and higher for empty trucks). The
effects of the project traffic as experienced by the receptors are
negligible (see Table 3.18) .
Tons per day of HC, SO,,, NO., and TSP emitted were .calculated .. based
upon vehicle miles traveled within the area. These values were compared
with BAAQMD levels of significance (LOS) as shown in Table 3.19. (Note
that LDS for air quality analysis is distinct from level of service [LOS]
for traffic analysis.) The increase from the project is negligible when
compared to the LOS. Nitrogen oxides levels are already above the BAAQMD
recommended level and the traffic emissions associated with the project
do not significantly impact the local air quality.
Mitigation Measures. See mitigation for cumulative impacts below.
3-124
136-03.R9 10/26/89
Impact Z - Cumulative Traffic,-Impacts in Project Area
The traffic volumes predicted for the ear 2005 were used to
P Y
estimate cumulative traffic impacts. The CALINE4 model was again used to
estimate CO concentrations in the Keller Canyon area (see Impact 1 -
Traffic Impacts from Project) . The results of the dispersion model are
presented in Table 3.20. Tons per day of HC, SO, NO,, and TSP emitted
were calculated based upon vehicle miles traveled within the area in the
year 2005. These values were compared with county-wide emissions (BAAQMD
1985) . As shown in Table 3.21, levels of hydrocarbons, particulate,
sulfur dioxide and nitrogen oxides are well below (less than 1 percent
of) Contra Costa County emission levels. Because emissions in the
project area would not increase County-wide emissions substantially this
impact would not be significant.
Mitigation Measure. The use of transfer stations would reduce
local traffic-related air emissions by reducing traffic to the landfill
itself. Further measures to reduce cumulative- traffic emissions in the
project area are beyond the applicant's control .
The following measures can be implemented by local transit agencies
to provide reductions in traffic and associated air emissions. The park
and ride facility planned for the Bay Area Rapid Transit (BART) station
near Highway 4 will help decrease the freeway traffic. Bicycle lanes
should be installed along all major roadways leading to the station.
Bicycle lockers should be readily available at the BART station. Buses
and vans should be scheduled to allow commuters-convenient transportation
to and from the BART station. Minibuses should be scheduled 'to service
all major housing subdivisions. Mass transit pick up stations should be
conveniently located, have benches and windscreens, and where possible,
pay telephones and drinking fountains.
Additional lanes on Highway 4 will relieve a great deal of
congestion on this roadway. As motor vehicles increase their speeds,
their CO emissions per mile decrease so all roadway improvements will
OEM
3-125
136-03.R9 10/26/89
TABLE 3.18
MAXIMUM PROJECT CO CONCENTRATIONS
IN THE KELLER CANYON AREA
Background Background
Maximum and Project Standards
Averaging Impact Maximum Impact California Federal
Period ppm ppm ppm ppm
One-Hour 6.0 6.1 20 35
Eight-Hour 4.2 4.3 9 9
TABLE 3.19
PROJECT AND BACKGROUND AUTO EMISSIONS
IN THE KELLER CANYON AREA
Background
Background and Project
Traffic Traffic Level of
Emissions Emissions Significances
Pollutant Tons/Day Tons/Day Tons/Day
Hydrocarbons 0.0675 0.0676 0.0750
Nitrogen Oxides 0.2462 0.2463 0.0750
Sulfur Dioxide 0.0399 0.0399 0.0750
Particulate Matter 0.0513 0.0513 0.0750
alevel of Significance (LOS) as determined by SAAQMD (1985). Exceedance of LOS by a project requires
Best Available Control Technology (BACT) to be used as a mitigation measure.
TABLE 3:20
i MAXIMUM CUMULATIVE CO CONCENTRATIONS
IN THE KELLER CANYON AREA
Maximum
Cumulative Standards
Averaging Impact California Federal
! i Period ppm PPM Ppm
i � One-Hour 10.2 20 35
Eight Hour 7.1 9 9
i
1
3-126
136-03.R9 10/26/89
TABLE 3.21
CUMULATIVE AUTO EMISSIONS
IN THE KELLER CANYON AREA
Cumulative Contra Costa
Traffic Emissions County-Wide
Pollutant Tons/Day Emissions
Hydrocarbons 0.104 126
Nitrogen Oxides 0.376 158
Sulfur Dioxide 0.061 74
Particulate Matter 0.078 83
help. Signal lights should be timed for a smooth flow of traffic. Low
volume intersections should have vehicle detection devices installed so
lights may be changed to accommodate the vehicles present.
Impact 3 - Fugitive Dust
While there are several sources of PM10 in the vicinity of the
project site (combustion of fossil fuels, industrial processes, fugitive
dust from transportation and construction), landfill construction and
daily operations would result in increased fugitive dust levels which
would directly contribute to higher PM10 levels in the area.
Fugitive dust emissions were calculated for onsite sources. These
include paved and unpaved roads, dust from operation activities and dust
from daily covering. Total uncontrolled fugitive dust emissions
(assuming no dust-control measures) were calculated for a worst-case
scenario using EPA emission factors (EPA 1985, Vol . I). Total
uncontrolled fugitive dust emissions are summarized in Table 3.22.
Without control measures this would be a significant level of emissions.
Mitigation Measures. Unpaved roads would be watered, and when
appropriate during the dryer seasons, a mixture of magnesium chloride and
water, which does not pose air quality hazards, would be applied to allow
a thick crust to form. Paved roads would be washed to remove tracked on
dirt. Storage piles emissions will be negated by the application of a
3-127
136-03.R9 10/26/89
TABLE 3.22
UNCONTROLLED° FUGITIVE DUST EMISSIONS
FOR KELLER CANYON LANDFILL
Level ofb
Emissions Significance
Source Tons/Day Tons/Day
Unpaved Roads 0.208
Paved Roads 0.155
Operating Activities 0.080
Total 0.444 0.075
°levels of uncontrolled emissions calculated assuming no implementation of mitigation measures.
b(BAAQMD. 1985).
latex sealer. Emissions from construction activities, excavation, daily
coverings, and storage pile disturbances would be reduced by chemical
application and watering. Revegetation would take place as soon as
possible, but no later than the first rainy season after final cover is
placed. A summary of the dust emissions using these measures appears in
Table 3.23. A minimum 90 percent reduction (EPA 1985, Vol . I) was
assumed to be achievable, resulting in a reduction of emissions to a less
than significant level .
TABLE 3.23
CONTROLLEDa FUGITIVE DUST EMISSIONS
FOR KELLER CANYON LANDFILL
Level ofb
Emissions' Significance
Source Tons/Day Tons/Day
Unpaved Roads 0.021
Paved Roads 0.016
Operating Activities 0.008
Total 0.045 0.075
'Controlled emissions calculated assuming implementation of mitigation measures.
b(BAAQMD, 1985).
3-128
136-03.89 10128189
t
Impact 4 - Construction and Operation Vehicle Emissions
Several types of heavy duty construction vehicles would be used to
level refuse, create berms and place cover. It is estimated that sixteen
scrapers, ten D9 bulldozers, two 07 bulldozers, and six compactors would
be used; on site (CH2M Hill 1989). These vehicles would be used an
average of 10 hours a day, 365 days a year and would emit carbon
monoxide, hydrocarbons, nitrogen oxides, sulfur oxides and particulate.
Emissions were calculated using EPA emission factors and are summarized
in Table 3.24 (EPA, 1985, Vol . II) . If vehicles are not tuned and
maintained properly emissions of nitrogen oxides would exceed levels of
significance.
TABLE 3.24
EMISSIONS FROM HEAVY DUTY CONSTRUCTION EQUIPMENT
Emissions from Level ofd
Construction Vehicles Significance
Pollutant Tons/Day Tons/Day
Carbon Monoxide 0.0245 0.2750
Hydrocarbons 0.0068 0.0750
Nitrogen Oxides 0.0775 0.0750
Sulfur Oxides 0.0091 0.0750
Particulate Matter 0.0071 0.0750
a(BAAQMD. 1985)
Mitigation Measures. All equipment used on site would be properly
tuned and maintained to reduce diesel combustion emissions. As cleaner
diesel fuels are developed, they would be used. When equipment is not
being used, it would not be left idling. These measures would reduce
emissions up to 50 percent and should reduce emissions of nitrogen oxides
to an insignificant level .
Impact 5 - Flare Emissions
The flare used to burn the landfill gas would emit by-products of
the combustion process. These by-products include particulates, sulfur
3-129
136-03.R9 10/26/89
OR
I
dioxide, nitrogen oxides, and carbon monoxide. Assuming a landfill gas
collection efficiency of 75 percent and a gas destruction efficiency of
90 percent, emissions were calculated under uncontrolled operating
conditions. Emission rates established by the U.S. Environmental
Protection Agency for natural gas combustion were used (EPA 1985 Vol .
I1). Natural gas consists primarily of methane as does landfill gas and
has many of the same minor constituents. As shown in Table 3.25,
nitrogen oxides would exceed BAAQMD level of significance. This would
trigger the use of Best Available Control Technology (BACT).
Mitigation Measures. For mitigation using BACT the flare should be
installed with staged combustion and operated under "fuel rich"
conditions. The flare should be designed with flue gas recirculation.
The emissions under controlled operating conditions are summarized in
Table 3.26. The emissions of nitrogen oxides would be reduced to a less
than significant level .
TABLE 3.25
ESTIMATED EMISSIONS FROM LANDFILL GAS FLARE
I
1
Emissions from Level ofa
Flare Significance
Pollutant Tons/Day Tons/Day
i
Carbon Monoxide 0.1285 0.2750
' Hydrocarbons 0.0213 0.0750
I Nitrogen Oxides 0.5145 0.0750
Sulfur Dioxide 0.0020 0.0750
Particulate Matter 0.0185 0.-0750
i
alevel of significance (LOS) as determined by BAAQMfD (1985). Exceedance of LOS by a project requires
Best Available Control Technology (SACT) to be used as a mitigation measure.
a
mnact 6 - To#al Landfill Emissions
Each of the individual project impacts have been described and when
possible quantified above. According to CEQA guidelines, total project
1 impacts must be addressed. The total amount of project criteria
i pollutants emitted by landfill traffic, construction and operation
equipment, and the gas flare is summarized in Table 3.27. As shown in
ii 3-130
136-43.89 10/26/89
..wl
TABLE 3.26
CONTROLLEDa EMISSIONS FROM LANDFILL GAS FLARE
Controlled Emissions Level ofb
from Flare Significance
Pollutant Tons/Day Tons/Day
Carbon Monoxide 0.1285 0.2750
Hydrocarbons 0.0213 0.0750
Nitrogen Oxides 0.0515 0.0750
Sulfur Dioxide 0.0020 0.0750
Particulate Matter 0.0185 0.0750
aControlled emissions calculated assuring implementation of Best Available Control Technology (SACT).
blevel of Significance (LOS) as determined by BAAQMD (1985). Exceedance of LOS by a project requires
BACT to be used as a mitigation measure.
TABLE 3.27
TOTAL PROJECT EMISSIONSa
Project Level ofb
Emissions Significance
Pollutant Tons/Day Tons/Day
Carbon Monoxide 0.1543 0.2750
Hydrocarbons 0.0282 0.0750
Nitrogen Oxides 0.5921 0.0750
Sulfur Dioxide 0.0111 0.0750
Particulate Matter 0.4696 0.0750
*Sum of emissions from landfill traffic, equipment, and landfill gas flare.
bBAAQMD 1985
the table, nitrogen dioxide and particulate emissions would exceed levels
of significance, which would trigger BACT use.
Mitigation Measure. As described in the previous mitigation
measures, nitrogen dioxide and particulate emissions can be reduced by
using control technology and dust suppression measures. Also, as
previously indicated, other pollutants can be reduced. using control
measures described above emissions can be reduced to less than
significant levels for all pollutants but nitrogen oxides (see Table
' 3.28 . Emissions of nitrogen oxides would be a significant unavoidable
�!! 3-131
136-03.R9 10/26/89
i
j adverse impact. Because only the landfill gas flare would be subject to
a permit from the BAAQMD, this exceedance would not trigger the need for
!. emissions offsets. The BAAQMD does not issue permits for mobile sources
such as vehicles and construction equipment.
TABLE 3.28
CONTROLLED TOTAL PROJECT EMISSIONSa
Controlled Project Level ofb
Emissions Significance
Pollutant Tons/Day Tons/Day
Carbon Monoxide 0.1421 0.2750
Hydrocarbons 0.0248 0.0750
Nitrogen Oxides 0.0903 0.0750
Sulfur Dioxide 0.0066 0.0750
Particulate Matter 0.0671 0.0750
! ;t aControlled emissions calculated assuming implementation of mitigation measures for traffic,
equipment, and landfill gas flare.
I' I
bBAAQMD 1985
f
` Impact 7 - Odors
4
Garbage, sewage sludge, and other materials in solid waste are
I
capable of producing odors at the working face before they are covered.
i
Uncontrolled landfill gas is also a source of odors at landfills. There
is potential for odors to be detected by area residents outside the
Keller Canyon Landfill boundary line. Odor thresholds for representative
Y
compounds are presented in Table 3.29.
� j Mitigation Measures. To minimize the possibility of odors detected
li beyond the property boundary, the working face of the landfill would be
j kept as small as possible. Cover would be placed daily and will be well
compacted. Sewage sludge and any odorous loads would be covered as
quickly as possible. The leachate collection system would be enclosed.
! � The landfill gas collection and flare system would help to prevent LFG
from becoming a source of odor. Collectively, these measures should be
effective in reducing the potential impact to a less than significant
level .
3-132
136-03.R9 10/26/89
a
IA
' TABLE 3.29
ODOR THRESHOLDS FOR REPRESENTATIVE COMPOUNDS
Compound Odor Thresholda(ppm)
Benzene 4.68
Carbon Tetrachloride 21.0
Chloroform 200.0
Dichloropropane 50.0
Ethylene Dichloride 120.0
Methyl Chloroform 21.0
Methylene Chloride 150.0
Perchloroethylene 4.68
Trichloroethylene 21.4
aThe minimum concentration which is detectable by 50 percent of the general population.
Source: Raijhans, 1985.
If odors are detected
beyond the property line, local residents
Y
would be able to telephone a landfill employee designated by the landfill
operators. The telephone number would be published in local telephone
directories and provided to area residences yearly either by flyer or
local newspaper publication.
It would be the duty of the designated employee to log the phone
call . The employee would immediately investigate the location of the
odor and determine its source. Remedial actions would be taken to
correct the problem and procedures would be implemented to prevent a
recurrence of the odor generating problem. The landfill employee also
would respond to the Citizen complaint -in writing ' within 48 hours
detailing the cause of the odor and what steps have been taken to prevent
a recurrence of the problem. Remedial measures could include more
frequent covering of waste loads or new handling procedures for problem
Rloads.
The complaint response process described here for odors would also
be applicable to other complaints.
3-133
136-03.R9 10/26/89
Impact 8 - Landfill Gas Emissions
As describedP reviously, the anaerobic decomposition of solid
wastes in landfills produces gases. These gases would be collected using
the system described in the Project Description (Chapter 2) . This would
be an active system in which the gas is mechanically induced to flow
through the collection system by a electrically powered blower. A flare
would be constructed to burn the collected gas.
In the past, it was conventional practice to vent landfill gas into
the atmosphere.
An air quality health risk assessment of the Keller Canyon Landfill
Project emissions of toxics in landfill gas was prepared by CH2M Hill on
behalf of the applicant. The full risk assessment is available for
inspection at the offices of the Contra Costa County Community
Development Department, 651 Pine Street, Martinez. This risk assessment
was prepared in accordance with BAAQMD guidelines. The list of toxic air
contaminants (TACs) considered in the risk assessment was provided by
BAAQMD as were the emission rates of these compounds. A peak landfill
gas generation rate of' 7,562 standard cubic feet per minute was estimated
for the Keller Canyon Landfill (CH2M Hill 1989) Table 3.30 summarizes
these compounds and their emission rates. The methods used in the risk
assessment were BAAQMD approved.
TABLE 3.30
TOXIC AIR CONTAMINANTS AND ESTIMATED EMISSION RATES
FOR KELLER CANYON LANDFILL RISK ASSESSMENT
Uncontrolled
Emission Factor
Compound (lbs/103 ft3) -
Benzene 0.0006 1
Carbon Tetrachloride 0.00000457 J
Chloroform 0.00005
1,1-Dichloroethane 0.001
1,1-Dichloroethene 0.0002
1,2-Dichloropropane 0.002
Methyl Chloride 0.0009
Methylene Chloride 0.007
Perchloroethylene 0.004
Trichloroethylene 0.0011
Vinyl Chloride 0.001
3-134
136-03.R9 10/26/89
Two air quality dispersion inodels were used in the screening
analysis: the Industrial Source Complex - Short Term (ISCST) model and
the VALLEY model . ISCST was used to compute the maximum ground level
pollutant concentrations on terrain lying at or below the mean elevation
of the landfill . VALLEY was used to compute the maximum ground level
pollutant concentrations on terrain lying above the mean elevation of the
landfill . Both models are EPA-approved.
Two types of emission sources were modeled at the landfill : gas
escaping throughout the landfill and gas emissions from the flare.
Theoretical receptors were placed 100 meters apart along a 2,600 meter by
4,000 meter rectangle encompassing the site boundary for ISCST modeling.
A total of 1,107 ground level receptors were evaluated in this grid.
Refined 50-meter spacing was used to evaluate maximum impact locations.
In VALLEY, receptors were placed along radial lines extending outward
from the flare source. Ten receptors were chosen at elevations of 900,
950, 1000, 1050, 1100, 1150, 1200, 1250, 1300 and 1350 feet above mean
sea level . The distance to each receptor was determined by taking the
distance from the flare to the closest topographic contour with the
desired elevation. Model results were normalized and combined for total
emissions. A gas destruction efficiency of 90 percent for the flare and
a landfill gas collection efficiency of 75 percent was conservatively
assumed. (Higher collection efficiencies may be achieved through use of
Best Available Control Technology.)
The maximum concentrationP redicted by either model at a
residential location for one-hour is 52.7 pg/m3 and the annual average
concentration is 5.3 pg/m3. The excess lifetime cancer risk was
calculated by multiplying the annual average concentration by the
individual TAC emission rate. The individual TAC annual average lifetime
concentration was multiplied by its individual unit risk value. The
cancer risks for different carcinogenic compounds at a single location
are assumed to be additive, so the total inhalation risk is the sum of
the risks from each individual chemical . These calculations are
summarized in Table 3.31.
3-135
136-03.R9 10/26/89
t
TABLE 3.31
CANCER RISK FOR ANNUAL AVERAGE CONCENTRATION
FOR NEAREST POSSIBLE RESIDENT
Annual Unit Excess
Average Cancer Lifetime
Concentration Risk Cancer
Compound (14g/m3) (per µg/m3) Risk
Benzene 0.019 8.3 x 10-6 4 x 10-7
Carbon Tetrachloride 0.0015 1.5 x 10-5 6 x 10-9
Chloroform 0.016 2.3 x 10-5 1 x 10-7
1,1-Dichloroethane 0.32 -- --
1,1-Dichloroethene 0.063 5.0 x 10-5 9 x 10-7
Methylene Chloride 2.2 4.1 x 10-6 3 x 10-6
Perchloroethylene 1.3 5.8 x 10-7 2 x 10-7
1,2-Dichloropropane 0.63 -- --
Trichloroethylene 0.35 1.3 x 10-6 1 x 10-7
Vinyl Chloride 0.32 4.2 x 10-5 4 x 10-6
Total 8 x 10-6
Source: CH2M Hill 1989
One important output of the cancer risk analysis is an estimate of the
highest increased cancer risk that any individual could expect over his
or her lifetime from exposure to emissions of the proposed landfill . For
locations at which individuals are exposed, this "excess lifetime cancer
risk" is the sum of the excess cancer risk due to inhalation of
individual airborne carcinogens. Risks due to non-inhalation pathway
ingestion through soils and crops were not applicable to this project and
are therefore insignificant. The excess risk due to inhalation of an
emitted carcinogen is a function of (1) the long-term estimates of the
ambient concentrations of the carcinogen at a given location (ISCST and
VALLEY models), (2) the carcinogen's unit risk value (see next paragraph
for explanation), and (3) the length of the exposure period. Excess
lifetime cancer risk values are a function of exposure, time, and
concentration. The excess lifetime cancer risk values associated with
concentrations of carcinogens for a specified time interval at a given
location are not necessarily additive with the risk at other locations
i
3-136
136-03.R9 10/26/89
66 ---
W
affected by the landfill . Moving from a location. subject to carcinogenic
exposure from a proposed project to another location not impacted by the
project would not decrease the already acquired risk. However, moving to
a location not affected by the project would eliminate the acquisition of
additional risk from the landfill .
A unit risk value is a measure of a substance's carcinogenic
potency. Values have been developed for a number of substances by either
the EPA's Carcinogen Assessment Group (CAG) or the California Department
of Health Services (DHS) . The value is defined as the estimated
probability of a person contracting cancer as the result of constant
exposure to an ambient concentration of 1 pg/m3 over a 70-year period.
The derivation of the carcinogenic potency values for each substance
takes into account the available information in pharmacokinetics, the
mechanism of carcinogenic action, and the effect of different models on
low dose extrapolation.
For substances which have been evaluated by both DHS and the EPA,
the unit risk value derived by the DHS is the value recommended for toxic
air pollutant health assessments. The DHS unit risk values provided in
Table 3.31 are generally 95 percent upper confidence limits on the unit
risk value. For DHS-generated values, DHS recommends that applicants use
only the 95 percent upper confidence limits on risk, rather than "best
estimates" or maximum likelihood estimates, when performing risk
assessments. For substances which have not yet been reviewed by DHS,
unit risk values derived by the EPA's CAG should be used. These
estimates are either best estimates (epidemiological studies) or upper 95
percent confidence (animal studies), depending on the findings of the
CAG. CAG unit risk values are recommended for use until these substances
have been evaluated by DHS. The unit risk values representing 95 percent
upper confidence limits that are presented in Table 3.31 are considered
health-protective, that is, the actual excess cancer risks are not likely
to be higher than those estimated. They could be considerably lower.
The cumulative excess lifetime cancer risk of the various landfill
Noe-
gas compounds listed by BAAQMD to be considered in the risk assessment
has been estimated to be eight additional cases of cancer per one million
3-137
136-03.R9 10/26/89
t
people (i .e. , a chance of eight in one million). This calculation
assumes a continuous exposure at the maximum predicted residential level
to an individual over a 70-year lifespan and assumes that risks for each
individual compound are additive. Significant risk was defined by BAAQMD
as one excess cancer case per million (BAAQMD Air Toxics Policy) . Due to
the projected cancer risk from the landfill gas emissions, this impact
would be considered an unavoidable significant impact.
Another risk analysis was performed using a 9-year exposure
assumption rather than the 70-year exposure recommended by BAAQMD and
DHS. This assumption was made using the Exposure Factors Handbook
published by the U.S. Environmental Protection Agency (EPA 1989) . As
reported by the U.S. Census Bureau, 50 percent of the population live at
one location 9 years or less. Therefore, it is likely residents in the
area would only be exposed for a period of 9 years. For the 9-year
exposure period, exposure to the average maximum gas generation rate was
assumed. (Landfill gas generation varies through the life of the
landfill . ) Thus the 9-year exposure period is balanced by the use of
peak gas generation rates and by retaining worst-case assumptions of
relatively low gas collection and combustion efficiencies.
Though this risk scenario is not within BAAQMD guidelines, it is an
indication of the additional cancer risk most residents would be exposed
to. The risk calculated using this assumption is one additional cancer
case per one million people exposed at the maximum predicted residential
level for nine years.
Mitigation Measures. Because landfill design has already
incorporated a state of the art gas collection system, it is anticipated
that the actual efficiency of gas collection and combustion would be
better than the efficiencies assumed in the BAAQMD risk assessment
guidelines. To affort an extra measure of health protection these
guidelines assume only a 75 percent gas collection efficiency. Actual
efficiencies of 90 percent may be achieved. Although BAAQMD guidelines
for risk assessments do not allow assumption of attaining maximum
efficiencies through use of Best Available Control Technology (SACT), the
actual design of the landfill would use BACT for gas control .
3-138
136-03.R9 10/26/89
i
TABLE B14
PEAK HOUR TRAFFIC VOLUMES
USED TO ESTIMATE TRAFFIC EMISSIONS
Existing Project Cumulative
Bailey Road South 560 2 920
of landfill access road
Bailey Road between Leland Road 1,370 35 2,210
and Highway 4 Underpass
Bailey Road Highway 4 Underpass 1,045 18 1,925
Bailey Road North of 720 1 1,640 .
Highway 4 Underpass
Bailey Road between Landfill 560 38 920
Access Road&Leland Road
Highway 4 west of Bailey Road 5,800 28 9,100 .
Highway 4 east of Bailey Road 5,600 6 8,700
Leland Road 1,020 3 1,370
Proposed Landfill Access Road 0 40 40
source: Abrams Associates,1989
4- 19
144-01.R8 1/_30/90
and Stoneman Park. In addition, it would reduce the value of the Buffer Zone as
such, and be the cause of increased biological impacts to Canyons No. 2 and 3. It is
for these reasons,that this alternative route was not explored among the alternatives
presented in the DEIR.
Response to Comment B13
The following text is added to the mitigation measure for Impact 1 after the
sentence inserted by the way of Comment A6: 'This erosion control plan, togethen
with revegetation and grazing plans, would comprise an overall land reclamation
plan, which should be developed in consultation with the Resource Conservation
District and the USDA Soil Conservation Service."
BAY AREA AIR QUALITY MANAGEMENT DISTRICT
Response to Comment B14
The year modeled for the project was the year 2005. The assumed traffic volumes
are based upon evening peak hour traffic volumes provided by Abrams Associates
and are presented in Table B14. The maximum impact receptor point was used.
This receptor was located within 10 meters of the roadway just south of the Highway
4 underpass east of Bailey Road.
Response to Comment BIS
The sensitive receptors in the project area are indicated on Figure B15. The
sensitive receptors within the area modeled using CALINE4 were included as
receptor points. There were four schools, four planned schools, one retirement
home and one planned park along one of the major roadways. None of these points
were maximum points of impact. The highest CO concentrations estimated were at
the proposed park along Bailey Road. The CO concentrations predicted here for
project plus background and cumulative were 2.5:and 3.1 ppm respectively.
Response to Comment B16
An impact analysis of the proposed transfer stations is not within the scope of this
EIR. Environmental documentation for each individual transfer station would be
prepared prior to the development of these stations. An EIR has already prepared
for the approved interim Acme Transfer station, which would initially be the only
transfer station used for the Keller Canyon Landfill.
Response to Comment B17 .
The health risk assessment was recalculated using a gas generation rate of 52.1
cubic feet per second as recommended by the BAAQMD in their letter dated 23
January 1990. (Please refer to the Introduction of this document for a copy of the
BAAQMD letter). The revised calculated risk representing the increased probability
of contracting cancer for the maximally exposed individual over a lifetime of seventy
years is 3 in one million.
4- 18
144-01,R8 1/30/90
Response to Comment B18
Please refer to Response to Comment A24 and the recent BAAQMD letter
presented in the Introduction.
Response to Comment B19
The DEIR did note, in the last sentence of the first paragraph on page 3-138, that
the health risk assessment previously performed did represent a significant impact .
As noted in the BAAQMD letter presented in the Introduction of this document, the
revised health risk assessment performed under guidance from BAAQMD does not
estimate a significant impact.
Response to Comment B20
The landfill employee would instruct residents calling the landfill to log an odor
complaint to also call the BAAQMD odor complaint number and to notify .the
Contra Costa County Department of Public Health Services.
Response to Comment B21
Please refer to Responses to Comments Cll through C15. The DEIR does use
the maximum predicted residential exposure level in dispersion modeling.
Residential development would not be allowed in the Special Buffer Area. The
landfill gas flare provides 40 percent destruction efficiency of odorous compounds
collected by the gas collection system. Unfortunately, an exhaustive literature search
did not produce any quantitative data on the effectiveness of most of the control
measures proposed as odor mitigations for the Keller Canyon Landfill. It is
unreasonable to try to estimate the effectiveness of these measures without some
data upon which to base these estimates. Any estimates made would be nothing
more than informed guesses. However, odor control measures at the Puente Hills
Landfill have been successful.
Response to Comment B22
Due to the topography and geology of the canyon it is impractical to move the
landfill any farther away from the residential area than the currently proposed
location. The current location of the toe berm is designed to provide stability in
relation to the existing materials and slopes in the canyon. It takes advantage of the
natural narrowing of the canyon at that point. Please refer to the DEIR's Geology,
Soils, Topography and Seismicity section starting on page 3-34 for a full description
of the topographical limitations of the site. Wind data is presented in Responses to
Comment C5 through C9. Please refer to Response to Comment B16 regarding
environmental documentation for transfer stations.
Response to Comment B23
It is always possible for odor impacts to occur from landfill operations. However,
based on analysis of the project these impacts are deemed to be mitigable. The Final
and Draft EIRs present the best estimates of what those odors are likely to be and
several ways to mitigate these odors. None of the estimates made show significant
impacts from odorous compounds beyond the property line for the proposed project.
4- 20
144-01.R8 IM/90
ATTAC@�Tr B
Title 14 California Integrated Waste Management Board § 17258.73
HISTORY NOTE Authority cited:Section 40502,Public Resources Code.Reference:Sec-
t.New section filed 7-12-93 as an emergency,operative 7-12-93(Register 93, tion 40508,Public Resources Code;and Title 40,Code of Federal Regulations,
No.29).A Certificate of Compliance must be transmitted to OAL by 11-9-93 Section 258.29.
or emergency language will be repealed by operation of law on the following HISTORY
day. 1.New section filed 7-12-93 as an emergency;operative 7-12-93(Register 93,
2.New section refiled 11-9-93 as an emergency;operative 11-9-93(Register No.29).A Certificate of Compliance must be transmitted to OAL by 11-9-93
93,No. 46). A Certificate of Compliance must be transmitted to OAL by or emergency language will be repealed by operation of law on the following
4-26-93 or emergency language will be repealed byoperation oflaw on the fol- day.
lowing day. 2.New section refiled 11-9-93 as an emergency,operative 11-9-93(Register
3.Certificate of Compliance as to 11-9-93 order transmitted to OAL 3-8-94 and 93,No. 46). A Certificate of Compliance must be transmitted to OAL by
filed 4-19-94(Register 94,No.16). 4-26-93 oremergency language will be repealed byoperation of law on the fol-
lowing day.
§17258.24. Air Criteria. 3.Certificate of Compliance as to 11-9-93 order transmitted to OAL 3-8-94 and
(a)Owners or operators of all MSWLFs must ensure that the units do filed 4-19-94(Register 94•No. 16).
not violate any applicable requirements developed under a State Imple- § 17258.60. Closure Criteria.
mentation Plan (SIP) approved or promulgated by the Administrator, (a)RESERVED
United States Environmental Protection Agency,pursuant to section 110 (b)RESERVED
of the Clean Air Act,as amended. (c)RESERVED
(b)Open burning of solid waste,except for the infrequent burning of (d)The owner or operator must notify the board that a closure plan has
agricultural wastes, silvicultural wastes, landclearing debris, diseased been prepared and placed in the operating record no later than October
trees.or debris from emergency clean-up operations,is prohibited at all 9. 1993.or by the initial receipt of waste,whichever is later.
MSWT_F units. (e)RESERVED
Nora Authority cited: Sections 40502. 43020, 43021 and 43030,Public Re- (f)RESERVED
sources Code.Reference: Section 40508.Public Resources Code;and Title 40. (g)The owner or operator of all MSWLF units must complete closure
Code of Federal Regulations,Sections 258.24. activities of eacb MSWLFunit in accordance with the closure plan within
HISTORY 180 days following the beginning of closure as specified in§17763.Ex-
t.New section filed 7-12-93 as an emergency;operative 7-12-93(Register 93, tensions of the closure period maybe granted by the board if the owner
No.29).A Certificate of Compliance must be transmitted to OAL by 11-9-93 demonstrates that closure will,ofnecessity,take longer than
or emergency language will be repealed by operation of law on the following oroperator yae on g
day. 180 days and the owner or operator has taken and will continue to take
2.New section refiled 11-9-93 as an emergency;operative 11-9-93(Register all steps to prevent threats to human health and the environment from the
93.No. 46). A Certificate of Compliance must be transmitted to OAL by closed MSWLF unit.
4-26-93 or emergency language will be repealed byoperation oflaw on the fol-
lowing day. NoTE Authority cited:Sections 40502,43020,43021,43030,43501 and 43509,
3.Certificate of Compliance as to 11-9-93 order transmitted to OAL 3-8-94 and Public Resources Code.Reference:Section 40508,Public Resources Code;and
filed 4-19-94(Register 94,No. 16). Title 40,Code of Federal Regulations,Sections 258.60.
HISTORY
17258.29. Reeordkeeping Requirements. 1.New section filed 7-12-93 as an emergency;operative 7-12-93(Register 93.
(a)The owner or operator of a MSWLF unit must record and retain No.29).A Certificate of Compliance must be transmitted to OAL by 11-9-93
or emergency language will be repealed by operation of law on the following
near the facility in an operating record or in an alternative location ap- day.
proved by the board the following information as it becomes available: 2.New section refiled 11-9-93 as an emergency;operative 11-9-93(Register
(1)Any location restriction demonstration required under Subpart B 93,No. 46). A Certificate of Compliance must be transmitted to OAL by
4-26-93 or emergency language will be repealed by operation of law on the fo i-
of 40 CFR Part 258 or trader§17258.10 of this article; lowing day.
(2) Inspection records, training procedures, and notification proce- 3.Certificate of Compliance as to 11-9-93 order transmitted to OAL 3-8-94 and
dures required in§17258.20 of this article; filed 4-19-94(Register 94,No.16).
(3)Gas monitoring results from monitoring and any remediation plans §17258.61. Postclosure Care Requirements.
required by§ 17258.23 of this article; (a)RESERVED
(4)Any MSWLF unit design documentation for placement of leachate (b)RESERVED
or gas condensate in a MSWLF trait as required under 40 CFR (c)RESERVED
§258.28(a)(2): (d)The owner or operator must notify the board that a postclosure plan
(5)Any demonstration.certification,finding monitoring,testing,or has been prepared and placed in the operating record no later than Octo-
analytical data required by Subpart E of 40 CFR Part 258; ber 9. 1993.or by the initial receipt of waste.whichever is later.
(6)Closure and postclosure care plans as required by§18255,notice NOTE:Authority cited:Sections 40502.43 020,43021,43030.43501 and 43509.
of intent to close the unit as required by§17768,notice of certification Public Resources Code.Reference:Section 40508.Public Resources Code:and
of closure as required by§ 18275,deed notation as required by§17787, Title 40,Code of Federal Regulations,Sections 258.61.
demonstration of release from postclosure maintenance as required by emergency;
§17788,and any monitoring,testing,or analytical data as required by 40 1.New section fried 7-12-93 m li emergency;operative d to O 3(Register 93,
No.29).A Certificate ofCompliance must be transmitted to OAL by I 1-9-93
CFR§258.61:and or emergency language will be repealed by operation of law on the following
(7) Any cost estimates and financial assurance documentation re- day.
quired by§§ 17258.73, 17258.74, 18263,and 18266. 2.New section refiled 11-9-93 as an emergency:operative 11-9-93(Register
93,No. 46). A Certificate of Compliance must be transmitted to OAL by
(8)Any information demonstrating compliance with the small com- 4-26-93 3or emergency language will be repealed by operation oflaw on the fof-
munity exemption as required by 40 CFR§258.1(f)(2). lowing day.
(b)The oner`operator must notify the board when the documents 3�Certificate ofCompliance as to I 1-9-93 order transmitted to OAL 3-8-94 andowner/operator
from paragraph(a)of this section have been placed in or added to the op- filed 4-19-94(Register 94,,No. 16).`
erating record.and all information contained in the operating record must § 17258.73. Financial Assurance for Corrective Action.
be furnished upon request to the board or be made available at all reason- (a)An owner or operator of a MSWLF unit required to undertake a cor-
able times for inspection by the board. rective action program under 40 CFR§258.58 must have a detailed writ-
(c)The board can set alternative schedules for recordkeeping and noti- ten estimate.in current dollars,of the cost of hiring a third party to per-
fication requirements as specified in paragraphs(a)and(b)of this sec- form the corrective action in accordance with the program required under
tion, except for the notification requirements in § 17258.10(b)and 40 40 CFR§258.58.The corrective action cost estimate must account for
CFR§258.55(g)(1)(iii). the total costs of corrective action activities as described in the corrective
t Page 731 R,0-,1)4 N..t6:,-==-41
ATTACBMM C
Title 14 California Integrated Waste Management Board 17671
17658. site security.
Article 7.3. Disposal Site Records The site shall have a perimeter barrier or topographic constraints de-
signed to discourage unauthorized entry by persons or vehicles.Areas
within the site where open storage or pending of hazardous materials oc-
§17636. Weight/Volume Records. curs shall be separately fenced and properly identified to create an ade-
Each site operator shall maintain records of weights or volumes ac- quatc level of security,unless the daily deposition of wastes is conducted
cepted in a form and manner approved by the Enforcement Agency.Such under adequate supervision during the site operating hours and provided
records shall be accurate to within 10 percent and shall be adequate for said wastes ars covered by the end of the daily site operations.
overall planning purposes and for the specific purpose of forecasting the
rate of site filling. §17659. Access Roads.
Access roads shall have a reasonably smooth surface designed to mini-
17637. subsurface Records. mize the generation of dust and the tracking of material onto adjacent
All site operators shall maintain adequate records regarding length and paved public roads.Such roads shall allow vehicles utilizing the site to
depth of any cuts made in natural terrain where fill will be placed,togeth- have reasonable all-weather access to the site.
er with the depth to the ground-water table.He shall also adequately re-
cord other cuts which may affect the safe and proper operation of the site §17660. Internal Roads.
or cause damage to adjoining properties. Internal roads,(i.e., within site fencing or other perimeter barrier)
which are used by the public shall be kept in safe condition,maintained
§17638. special Occurrences. such that vehicle access and unloading can be carried on during inclement
(H)Each operator of a site accepting an average of 100 or mors cubic weather,and identified with suitable signing showing directions to the
yards of wastes per operating day shall maintain a log of the following operating area.
information:fires,earth slides,unusual and sudden settlement,injury and
property damage accidents,explosions,discharge of hazardous or other Article 7.5. Disposal Site Operations
wastes not permitted in the class of site involved,flooding,and other un-
usual occurrences.
?)17666. sentCery Facilities.
17639. Inspection of Records. (H)Adequate sanitary facilities for the site personnel shall be available
The records shall be open to inspection by authorized representatives at the site or in the immediate vicinity.
of the Enforcement Agency,the local health entity and other duly autho-
rized regulatory and enforcement agencies during normal business 17667• Water Supply.
hours. (H)Safe and adequate drinking water for the site personnel shall be
available.
§17646. Availability.
HIsroRY §17668. Communications Facilities.
1.Change without regulatory effect remunbering Section 17646 to Section 17671 Each site where hazardous wastes ars accepted or where personnel are
filed 8-17-89 pursuant tc Section 100,Title 1.California Code of Regulations on duty shall have communication facilities available to users and to site
(Register 89,No.35).For prior history,see Register 78,No.30. personnel to allow quick response to emergencies by the appropriate au-
thorities and emergency services.If the facility accepts non-hazardous
17647. Training. wastes and is unattended,signs at the highway turnoff and at the entrance
HISTORY to the facility shall wain the users that no communications facilities are
1.Change without regulatory effect renumbering Section 17647 to Section 17672 available at the facility.
filed 8-1.7-89 pursuant to Section 100,Title 1,California Code of Regulations HISTORY
(Register 89,No.35).For prior history,see Register 78,No.30.
1.Arnerrdmrnt filch 7-25-78;effuxivethirtieth daythereaAer(Regtstec78.No.
¢17648. supervision. 30).
HISTORY 17669. Lighting.
1.Change without regulatory effect renumbering Section 17648 to Section 17673 Where operations are conducted during hours of darkness,the site and/
filed 8-17-89 pursuant to Section 100,Title 1.California Code of Regulations tri ant shall be tri with rate lighting as ved b the
(Register 89,No.35).For prior history,see Register 78,No.30. eq pm equipped �9 approved Y
Enforcement Agency to insure safety and to permit monitoring the effec-
§17649. site Attendant tiveness of cover and compaction operations.
HISTORY
1.Change without regulatory effect rrnumberingSection 17649 to Section 17674 17670. Personnel Health end safety.
filed 8-17-89 pursuant to Section 100.Title 1,California Code of Regulations (H)Operating and maintenance personnel shall be required to wear
(Register 89,No.35).For prior history,we Register 78,No.30. and use approved safety equipment as determirfed necessary by the En-
forcement Agency.
Article 7.4. Disposal Site Improvements §17671. Availability.
It is the responsibility of the operator of the site to provide adequate
17656. Identification signs. numbers of qualified personnel to staff the site and deal effectively and
Each point of access from a public road shall be identified by a suitable promptly with matters of operation,maintenance,environmental con-
sign indicating the name of the site operator.Other pertinent general in- T1s,records,emergencies,and health and safety.In this regard.cross-
formation may be required by the Enforcement Agency as approved by ming and development of standby arrangements are encouraged.
the local land use authority. NorE Authority cited:Section 40502.Public Resources Code.Reference:Sec-
tions 43020 and 43021,Public Resources Code.
117657. Entry signs. HrsroRY
If the site is open to the public,there shall be a sign at an appropriate 1.Change without regulatory effect renumbering forma section 17646 to section
int indicating the schedule of charges,hours of operation.and listing 17671 filed 8-17-89pursuant tosection 100.title 1.California Code ofRerAs-
po g $ Pe g tions(Register 89,No.35).For prior history,see Register 78.No.30.
the general types of materials which either(1)WU.1,be accepted or(2) 2.Change without regulatory effect amending section filed 5-17-91 pursuant to
WILL NOT be accepted. section 100,title 1,California Code of Regulations(Register 91,No.27).
t
Page 733 R.tWr 91 tm 15-17.4-24-92
O,n
.Contra '' Healti i Services Department
�. 1.,
ENVIRONMENTAL HEALTH DIVISION
Casty
a 1111 Ward Street
Count ��"'
�/ \�„>;... ,,-��”` Martinez.California 94553-1352
Y s>'�`2'o vtt
(510)646-2521
April 6, 1994
Lance Dow, Vice Chair
Citizens United
2232 Concord Drive
Pittsburg, California 94565
RE: Letter of March 24, 1994
Dear Mr. Dow:
This responds to your March 24, 1994 Public Records Act request to the Health Services
Department, Environmental Health Division (received March 28, 1994) for the "operating
records" of the Keller Canyon Landfill.
Based upon our understanding of what you describe as "operating records" of the Keller
Canyon Landfill, such documents are not maintained by this office.
l"
Your March 24, 1994 letter refers to Section 17258.29 of Title 14 of the California Code of
Regulations (CCR) and Section 258.29 of Title 49, Code of Federal Regulations (CFR),
Parts 257 and 258 as requiring this Department to obtain documents on your behalf. We
disagree with your assertion.
Both sections are entitled "Recordkeeping Requirements" and are virtually identical, except
that the federal regulations refer to the State Director instead of the Board. Section 17258.29
of Title 14 of the California Code of Regulations is attached. The following subsections
references are to section 17258.29.
Subsection (a)(1) This subsection relates to landfills within 10,000 feet from any airport
runway and therefore is not applicable to Keller Canyon Landfill.
Subsection (a)(2). Our inspections records are available for your review. (You have already
copied most if not all of our inspection reports.) Training procedures and notification
procedures are in the RDSI, which you have already reviewed. It is available for your review
again.
A373A (10/92)
Subsection (a)(3). Gas monitoring has not yet started, and is not required at this time.
Subsection (a)(4). Any design documentation for placements of leachate or gas condensate is
included in the RDSI and the Final Development and Improvement Plan, which are on file in
this Division and are available for your review.
Subsection (a)(5). Data maintained as required by this subsection is reported in the Quarterly
Self-Monitoring Reports, which you have reviewed on at least two occasions. The Reports
will be made available for your review again.
Subsection (a)(6). Closure and postclosure plans are maintained in this office and available
for your review.
Subsection (a)(7). Documentation on cost estimates and financial assurance documents are
maintained and available for your review.
Subsection (a)(8). This subsection is not applicable to Keller Canyon Landfill; therefore no
documentation exists.
For your information, the Keller Canyon Landfill Guidelines for Direct Haul have recently
been revised. The revision includes a requirement to report quarterly the waste type,
tonnage, and jurisdiction origin of direct haul loads. The reporting will apply to direct haul
loads received from this month on. The reports will be made available for your review in the
future.
Please call me at 646-2521 to make an appointment to review the above-noted documents.
Since] ,
Rebecca Ng, R.E.H.S.
Senior Environmental He Specialist
Attachments
cc: Lillian T. Fujii, Deputy County Counsel
06-20-1995 04:12PM FROM TO 96462535 P.02 F�
r /
:, BAVAREAAIRQU- -A.LITY
�~ NL4NAGEMENT DISTRICT
ALAMEDA COUNTY
EowarC A.CampDeU
Shirley-L campW1
Chuck C,gri{:a ' January 24, 1990
Frank H.Ogawa
CONTRA COSTA COUNTY
Paul L.Cooper
(Secretary)
Sunne Wright McPsak
MARIN COUNTY Mr..Ciledes A.Zahn
At AramOuru Assistantbireiitor of Community Development
NAPA COUNTY Contra costa County
ftb white 651 Pine Street
SAN FRANCISCO COUNTY; -4th Floor North Win
r�r.y G.arm. ��. g
Jim Gonzalez' Maitin$2,CA 94553
'01 SAN MATEO COUNTY
Gus 1_Nicotopulos
Anne rWwo Subject: Keller Canyon Risk Assessment
SANTA CLAAA COUNTY t..
Martha Clevenger
RW Diii&n Oe&r fir.Zahn!
Rogerla'H.Hu9han
Susanne vvf>gpri
SOLANO COUNTY With reference to the above subject the District's comments are as follows. Please note
oseyOavis that.this letter supersedes the December 21, 1989 letter written' from the District, with
(viceCTairperso°) reference to the health risk assessment addressed in the letter_
SONOMA COUNTY
Jim Harberson Review of the risk assessment in the Draft Environmental Impact Report (DEIR) showed
that the Unit Risk Factors used for Benzene,Carbon Tetrachloride and Vinyl Chloride and
the calculated gas generation rate were inconsistent with the District's current Guidelines,
n These inconsistencies were corrected and the attached table presents the parameters
used in the November 1989 submittal and the revised submittal of January 17, 1990,
M
Conclusion and.Remarks.-
The calculated risk represents the increased probability of contracting cancer for the
maximally exposed individual over a lifetime (70 years) through the inhalation pa.nvay.
For toxic sources applying Toxic Best Available Control Technology(TRACT), the District
has established a threshold of 10 in a million to decide on the significance of the impact.
The District bases the definition of significance upon Proposition 65 definition of
'Significant Exposure"-
The estimated risk for Keller Canyon is 8.0 In a million. This agrees with new
a calculations submitted by the proponent on January 17,7990. The proposed site
employs TBACT and the risk does not exceed the 10 in a million threshold.The district
does not consider-this,impact to be significant for CEQA ourooses.
3
9
ld
E
i
939 ELLIS STREET • SA\ FRA\CISCO.CALIFORNIA 94109 (415) 771-6000
t
TO 96462535 P.03 •-
06-20-1995 04:12PM FROM
i
Contra Costa County
January 24,1990
Page 2 l
This risk assessment is a screening level assessment based on very conservative assumptions.
Conservative assumptions are made to eliminate underestimating the risk.'The actual risk is no �
greater then, and probably much`less than the risk reported here. Further refinements in the
model may result in lower estimate of the risk.
If you have any questions please call Had S.Doss at 415771-6000,extension-M-Thank you. j
Very truly yours i
Milton Feldstein
Air Pollution Control Officer
MF,.HSD:ls
i
' I
I
06-20-1995 04.12PM FROM TO %462535 P.04
KELLER CANYON
PARAMETERS USED F6R MSK ASSESSMENT
PARAMMR REVISED NOVEMBER SUBMITTAL
Gas generation rate 52.1 126.0
vlftecj
Toxic emission factor BAAQMD Standards SAAQMD Standards
Unit risk fact6js SAAQMD Standards IRIS
Ground level concentration(uGmtM3):
(Fugitives+Stack) 5.3 5.3
Totat risk 3 in a million 9 in a million
oil
r
{
f
TOTAL P.04
r