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HomeMy WebLinkAboutMINUTES - 06061995 - D.1 D. 1 THE BOARD OR SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Adopted this Order on _June 6, 1995 by the following vote: AYES: Supervisors Rogers, Smith, DeSaulnier, Torlakson, Bishop NOES: None ABSENT: None ABSTAIN: None ---------------------------------------------------- SUBJECT: Keller Canyon Landfill In response to the request of the Board on May 16, 1995, the Health Services Director submitted the report prepared by the Local Enforcement Agency (LEA) of his Environmental Health Division relative to various waste Issues at the Keller Canyon Landfill operated by Browning-Ferris Industries (BFI) . Rebecca Ng of the (LEA) summarized the various components of the report. A copy of the report is attached and included as a part of this Board Order. Ms. Ng noted that Keller Canyon does have all their lab analyses in at least one file cabinet on site and has made them available to County personnel upon request. She referred to current discussions with BFI and their willingness to make them available to the Board, but she noted that BFI had some proprietary concerns about the lab results. Ms. Ng advised that the copy of the analysis attached with her report is a copy of an actual analysis performed. She explained that generally the results in an analysis such as this are compared to Title II Regulatory Limits and that if everything is under the regulatory limits, it is not considered hazardous and would be acceptable for disposal at Keller Canyon. V. Alexeeff, Director, Growth Management and Economic Development Agency, advised the Board that the testing procedures and reporting frequencies were established and authorized by the various State agencies with the County Health Department following the procedural steps of the State. In response to a question of Supervisor Bishop, Ms. Ng advised that currently Keller Canyon is not allowed to use contaminated soils for daily cover and is using as daily cover the soil excavated from on site. She explained that the Landfill operator had proposed to use contaminated soils for daily cover but was never given approval to do so and therefore withdrew his proposal in early May. In response to Supervisor Rogers' question relative to obtaining studies conducted by the Bay Area Air Quality Management Board (BAAQMD) in the area prior to the construction of the Keller Landfill, Ms. Ng advised that she would request them from the Air Board. In commenting on the dust issue, Mr. Alexeeff advised that dust is essentially governed by two factors--the wind and the extent to which the ground is overturned. He referred to the issue of dust at Keller and the extent to which the ground is overturned, the circumstances to which it is overturned and how the dirt is handled when it is exposed. Mr. Alexeeff commented on the elaborate watering process required at the Keller Landfill site. Ken Etherington of BFI advised that his company would provide the laboratory analytical information and contracts with the Landfill's customers. He voiced his Company's concern with not making their customers public due to competition and pricing. He agreed to provide the documentation requested while preserving the anonymity of their customers. Mr. Alexeeff referred to the workshop tentatively scheduled for June 20, 1995, in Pittsburg. He advised that the City of Pittsburg has indicated that it may not be productive to hold the workshop at this time. Mr. Alexeeff advised that in order to make sure that there is a procedure in place for evaluating Keller's Land Use Permit, he planned on recommending to the Board on June 13, 1995, criteria under which the Planning Commission will conduct the Land Use permit review. The following persons spoke: Mary Erbez, Councilwoman, City of Pittsburg, 2020 Railroad Avenue, Pittsburg; , Frank Aiello, Citizens United, 1734 Bridgeview, Pittsburg; and Bob Maes, 2290 Jacqueline Drive, Pittsburg. All persons desiring to speak were heard. Supervisor Torlakson requested that on the June 13, 1995, Board Agenda there be listed a formal request for BFI to make available copies of the Keller Canyon Landfill's contracts. Supervisor Torlakson proposed that the issues relative to Keller's Land Use Permit review process be discussed at the Board evening meeting on June 20, 1995, with the cities of Concord, Clayton, and Pittsburg being invited to participate in the discussion. He advised that some of the data requested from BFI and certain staff reports would be available for this meeting which would also provide the opportunity for public input. THEREFORE, IT IS BY THE BOARD ORDERED that the report of the Health Services Director is ACCEPTED. IT IS FURTHER ORDERED that the Workshop on special wastes scheduled for the evening of June 20, 1995, at Pittsburg is DEFERRED to a later date. IT IS FURTHER ORDERED that the Director, Growth Management and Economic Development Agency (GMEDA) , is REQUESTED to report to the Board on June 20, 1995, 6 p.m. , on proposed criteria for evaluating the Keller Canyon Landfill Land Use Permit with invitations sent to the cities of Concord, Clayton, and Pittsburg for their participation in the discussion on this date. IT IS FURTHER ORDERED that the Health Services Director is DIRECTED to receive information provided by BFI and to make it available for public review with the GMEDA Director advising the Clerk of the Board of the review site. I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board of Supervisors on the date shown. cc: Director, GMEDA ATTESTED: �--� 6 ,. /9 9S Health Services Director PHIL BWTCHELOR,Clerk of the Board Environmental Health LEA of Supervisors and County Administrator Rebecca Ng County Counsel BY . — .Deputy Phil The Board of Supervisors Contra ClerkoahehBoard and County Administration BuildingCosta County Administrator 651 Pine St., Room 106 (415)646-2371 Martinez, California 94553 County Tom Powers,1st District Nancy C.Fanden,2nd District ti se.b Robert 1,Schroder,3rd District �'_ ',—•.o� Sunne Wright McPeak,4th District Tom Torlakson,5th District . r q Cour DATE: June 6, 1995 TO: Board of Supervisors FROM: Mark Finucane, Health Services Director SUBJECT: Keller Canyon Landfill The Board of Supervisors directed the Health Services Department to report on a number of issues that arose regarding Keller Canyon Landfill during the hearings of May 16, 1995 and May 23, 1995. This report addresses those issues. 1. Laboratory Analysis In order to dispose of designated wastes at KCLF, a waste generator must meet BFI's acceptance criteria. The acceptance procedure entails: Step 1: Generator must complete and sign a BFI Waste Approval Request form, including the Representative Sample Certification section which certifies that the sample is representative of the waste. (See Exhibit A.) Step 2: Generator must have a state certified laboratory perform analyses on representative samples of the waste material. Step 3: The lab analyses are reviewed by two separate groups of BFI technical waste approval coordinators. If the analyses are acceptable to both groups according to contaminant levels in the California Code of Regulations, Title 22, the generator is given a BFI Waste Code Number and authorization to dispose the material at Keller Canyon Landfill. Step 4: All vehicles arriving at the landfill will have a BFI Non-Hazardous Special Waste Manifest referencing the BFI Waste Code Number. (See Exhibit B.)The waste is inspected by KCLF personnel for conformity. If the waste conforms and the manifest is complete, the truck will be directed to the proper area to dispose of the waste. Exhibit C is an example of the lab analysis conducted on a sample of waste asphalt. Board of Supervisors Keller Canyon Landfill June 6, 1995 Page 2 2. Compliance Reports Exhibit D and E are reports submitted by Keller Canyon Landfill Inc. for verification of compliance with the guidelines imposed by the Board of Supervisors action of December 7, 1993. The compliance reports were required to be submitted every six months. KCLF Inc. also submits to the Local Enforcement Agency (LEA) and the Community Development Department (CDD), quarterly reports which summarizes KCLF waste and tonnage information. 3. Special Waste Report Staff was directed by the Board of Supervisors to revise the May 16, 1995 staff report so that it would be more easily understood by the Public. Staff will have a two-page revision of the report for the public workshops. 4. Public Workshops County GMEDA and Health Services staff are working with the City of Pittsburg on the public workshops. They are attempting to form a panel to address Keller Canyon Landfill issues. 5. Dust Complaints The LEA staff has consulted with an Air Quality Engineer II at the Bay Area Air Quality Management District (BAAQMD) regarding Mr. Drummond's May 16 assertion that more dust emissions are created at night. Keller Canyon Landfill (KCLF) covers the waste received on a daily basis with a minimum of six inches of soil. The soil used for cover is excavated from a site on KCLF property and is applied on the waste at the end of each working day. The primary function daily soil cover is to prevent odors, nuisances, vectors, fires, and litter. The daily soil cover also promotes lateral runoff of precipitation and reduces infiltration of water and potential leachate generation. Contaminated soil is not used for daily cover at Keller Canyon Landfill. According to the BAAQMD, there is no evidence or reason that emissions of dust, odors etc., would increase at night. Additionally, an assumption can be made that the higher moisture content in the evening air results in dew which reduces or prevents dust from being emitted into the air. 6. Special Waste Vehicle Routes At the May 16, 1995 Board Hearing, Supervisor Torlakson had requested information regarding the route for special waste vehicle accessing KCLF. The access route for special waste vehicles is the same as that of the transfer vehicles transporting municipal solid waste from the transfer stations. Land Use Permit 2020-89, the Conditions of Approval for Keller Canyon Landfill identifies the access route in Condition 29.2. Condition 29.2 states, "Access to the landfill facility shall be via State Highway 4, and Bailey Road. No waste-hauling traffic Board of Supervisors Keller Canyon Landfill June 6, 1995 Page 3 shall be allowed entrance to the landfill from Bailey Road south of the site. The Landfill operator shall specify use of the prescribed route in all user contracts and shall notify non-contract users of the requirement." Additionally, all waste vehicles entering KCLF must meet Condition 8 which identifies the eligible refuse transport vehicles admitted to the Landfill. The types of vehicles approved for admittance to KCLF are: a. Transfer vans from a transfer station located in Contra Costa County; b. Demolition and construction debris material trucks; C. Incinerated sewage sludge hauling trucks; d. Sewage and water treatment plant sludge trucks; e. Vehicles hauling designated waste approved for disposal at Keller Canyon Landfill by the Regional Water Quality Control Board; f. Other specialized waste transport trucks, hauling waste as identified in the Solid Waste Facilities Permit for the landfill facility. All waste generators must adhere to direct haul procedures specified in the Guidelines for Direct Haul including covering or containing the waste properly. To our knowledge, all vehicles accessing KCLF have complied with Conditions 8 and 29.2. There have been two situations since the Landfill opened when waste vehicles were re-routed by on-site enforcement personnel under emergency situations. If there are questions related to this report, please contact Rebecca Ng at 646-1251. Attachments cc: William B. Walker, M.D., Health Officer Daniel M. Guerra, Deputy Director, Environmental Health BN2:BOS6.95 -i A, ®Waste EXHIBIT A 1 Systems TM BROWNING-FERRIS INDUSTRIES WASTE CHARACTERIZATION DATA-SPECIAL WASTE. This form is to be utilized to describe"Special Waste"offered to BFI for management,transportation,and/or disposal. "Special Wastes"are defined as any solid,liquid,semi-solid,or gaseous material and associated containers generated as a direct or indirect result of a manufac- turing process or from the removal of contaminant(s)from the air,water or land. These materials include but are not limited to: Wastes not included in this definition are: i • State regulated wastes, - General household wastes, • Asbestos wastes from manufacturing or chemical • Uncontaminated packaging material and uncontaminated processing facilities, construction or demolition debris from a building or • Industrial process wates, structure that is not involved with any manufacturing or • Pollution control wastes, chemical process, • Infectious wastes(untreated), • Landscape wastes, • Outdated products,and • Domestic sewage(does not include Wastewater Treatment Plant • Incinerator wastes. [WTP]sludge),and • Uncontaminated food or grain wastes. In accordance with US EPA rules under 40 CFR Part 262 and equivalent state,provincial,and local rules,generators must determine whether their waste is a hazardous waste. In order to manage your waste,BFI requires certain information about your waste to confirm your determination that it is not a hazardous waste and that it can be managed in a safe,environmentally sound,and lawful manner.This information will serve to protect you,the waste generator,as well as BFI.NOTE:This form is not to be used for hazardous waste or PCBs regulated by a federal or applicable state, provincial,or local authority. GENERAL INSTRUCTIONS 1. The BFI individual requesting approval is to complete the Waste Approval Request portion. 2. A representative of the generator must complete the Waste Characterization Data(WCD)portion of the form. Please be thorough in your answers. The entire form must be completed,answers must be legibly printed in ink or typewritten,and the completed form must be signed and dated.Check "N/A"where the data requested are not applicable,and"N/D"if the information has not been determined.Please attach any additional relevant information such as MSDS or analytical data that will help to describe the waste and expedite its review.Use this form only one time since this form has a unique WCD number assigned to it. 3. A representative sample of the waste to be managed by BFI may be required.A Representative Sample Certification(RSC),found at the bottom of page 4,must be completed to accompany any sample submitted to BFI or to certify that the sample for which analytical data are provided was representative of the waste to be managed by BFI. 4. Send the completed and signed form to your BFI Sales Office. If you have any questions concerning the completion of this form or the collection of a representative sample,please contact your BFI Sales Representative or call(800)753-5997. SECTION 1.-,GENERATOR,INFORMATION a) Generator's Name-Name of the company generating the waste. b) Generating Facility's Complete Address-Physical address including the street,city and state of the generating facility.Do not use P.O.Box numbers. c) Company Representative-The name of the generator's employee or authorized representative completing the form and their telephone and fax numbers.This person must also sign the form in Section 9. d) Emergency/Information Contact-Provide the name and phone number of the individual(s)representing the generator who may be contacted regarding emergencies(e.g.spills)or for any additional information. e) if the generating facility is regulated by a state,provincial,or local regulatory agency as a generator of a"Hazardous Waste",a"Special Waste",a "Pollution Control Waste",or an"Industrial Process Waste",note the registration number,if one has been assigned. If the facility also generates a RCRA hazardous waste,enter the Generator's USEPA Identification Number. Describe the industry in which the facility operates and enter the facility's Standard Industrial Classification(SIC)code. f-h) Customer Information-If the company to be billed is different than the generator,supply the customer's name,mailing address,individual to be contacted,and his/her telephone and fax numbers. SECTION 2-GENERAL WASTE STREAM=INFORMATION _. a) Name/Description of Waste-Describe the waste and the source from where it is generated. For example,sludge from a biological treatment system clarifier,tank bottoms from crude oil storage tank,solidified epoxy paint from spray booth,etc. Please be as thorough as possible. b) Process Generating Waste-Describe the complete process,not just the source of the waste. For example,municipal wastewater treatment plant,crude oil refining operation,furniture manufacturing,repair of a storage tank containing number 6 fuel oil,etc. Please be as thorough as possible. c) Indicate if the waste was previously a restricted hazardous waste which has been treated to render the waste non-hazardous. d) Indicate if the waste material is regulated by an applicable state,provincial,or local regulatory agency as a"Hazardous Waste". If so,enter the Waste Identification Number,if one has been assigned. Materials designated as hazardous waste by the USEPA are not to be described on this form. e) Indicate if the waste material is regulated by an applicable state,provincial,or local regulatory agency as a"Special Waste",an"Industrial Process Waste",or a"Pollution Control Waste". If so,enter the Waste Identification Number,if one has been assigned. f) In accordance with OSHA Hazard Communication requirements(29 CFR 1910.1200)and Canadian WHMIS requirements,provide any special handling information,personal protective equipment recommendations.and other relevant information that will prevent injury or illness resuiting irom the management of the waste. If no information is provided, it is a declaration by the generator that the waste poses no health or safety hazard and can be handled safely without the use of personal protective equipment or special handling procedures. g) Anticipated Volume-The quantity and frequency of generation of the waste described is to be noted.Also,note the manner in which the waste is to be transported for disposal(e.g.,bulk,55 gallon drums,35 gallon fiber pack containers,etc.) h) Indicate if a representative sample of the waste has been provided to BFI. L' M SECTIOI 1STE PROPERTIES @,s1rF OR TiAMBIEN ;RATURE Indicate ranges if appropriate. a) Physical State-Check the appropriate physical state of the waste at ambient conditions. If the waste is bilayered,describe the type of physical states that make up the combination:e.g.,semi-solid and liquid. b) Check the box which best describes the number of layers associated with the waste. c) Color-Describe the color of the waste,or if non-homogeneous,the colors associated with the waste. d) Odor-Describe any obvious odor;for example,sweet,acidic,solvent. Describe the intensity of the odor(none,mild,strong). Note that you should not purposefully smell the waste,but any incidental odor noticed upon management of the waste is to be described. e) Density-Indicate the expected weight range of the waste per unit volume. If this has not been determined,check"N/D". f) Flash Point-If the waste is solid or powder,note"N/A". Otherwise,check the temperature range at which the waste exhibits a flash point. Do not check more than two(2)consecutive boxes. If this has not been determined,check"N/D". g) If the waste is aqueous,note its pH range. If the waste is non-aqueous,note non-applicable(N/A). No more than two(2)consecutive boxes may be checked. If this has not been determined,check"N/D". SECTION 4-REACTIVITY If the waste exhibits any of the following reactive properties,mark the appropriate box. • Water Reactive-Reacts violently,forms potentially explosive mitxtures,or generates toxic gases or vapors when exposed to water. • Acid or Alkaline Reactive-Releases heat,toxic gases or vapors when exposed to an acid(pH-2)or an alkaline(pH-12)environment. • Oxidizer-Reacts with organic matter to cause fires or smoldering. • Autopolymerizable-Hardens or solidifies without assistance,usually with a release of heat. • Pyrophoric-Ignites in air. • Explosive-Burns suddenly with violent results. • Thermally Sensitive-The hazardous or toxic properties may change with the application of heat. • Shock Sensitive-Detonates or explodes if jolted or dropped. • None of the above-The waste exhibits none of the reactive properties defined above. SECTION 5-WASTE.CONTAINS Indicate if any materials defined below are present in the waste:if so,type(s)(if applicable)and concentration(s)must be included as part of the waste composition in Section 6. • Free Liquids-The waste fails the Paint Filter Liquids Test(SW846,9095). • Free Cyanide;Free Sulfide;Free Ammonia-Hydrogen cyanide or hydrogen sulfide liberated when the waste is subjected to an environment with a pH of 2,ammonia liberated when the waste is subjected to an environment with a pH of 12.5. • Dioxins-Chlorinated dioxins,chlorinated dibenzofurans and tri,tetra,and penta-chlorinated phenols. • Organic Solvents-Aromatic and aliphatic hydrocarbon solvents such as alcohols,ketones,esters,ethers,benzene,mineral spirits,lacquer thinner,amines or chlorinated hydrocarbons. • Virgin Oils-Unused oils,for example,crude oil,fuel oil,diesel oil,mineral or edible oils. • Used Oils-For example,motor oils,lubricating oils,or cutting oils. • OSHA Substances-The compounds identified by federal health and safety authorities(i.e.OSHA in the U.S.,Labour Canada in Canada)as having occupational exposure limits. • Etiological Agents-A substance which causes disease or abnormal conditions in humans. • Pathogens-Disease causing organisms. • Biological Materials-Living or once living organisms,e.g.,bacteria,animal carcass. • Radioactive Materials-Naturally occurring or byproduct materials that emit radiation above background. • PCB's-Polychlorinated Biphenyl not regulated by TSCA,40 CFR 761.If yes,complete the BFI PCB Questionnaire. • None of the above-The waste contains none of the above. �{ s SECTION 6 SPECIAL WASTErCOMPOSITION " z, � a .w, �- Describe the components of the waste.Use common or generic terms describing the constituent concentrations in percentages('/o)or parts per million (ppm).Do not use abbreviations,Trade Names,or vague descriptions,such as,oil or sludge.If the total of all components does not equal 100%,the generator is claiming that the non-listed content(s)of the waste is inert and poses no hazard to the environment or to worker health and safety(e.g., water,soil,vegetation). SECTION'7-TRANSPORTATIONINFORMATION_ ,. If the waste is a USDOT Hazardous Material,the Proper USDOT Shipping Name,Hazardous Class,UN or NA Number,and CERCLA Reportable Quantity must be noted for manifesting and placarding purposes(see 49 CFR 172.101). • •. �, � �.,,. ...:- f-'i `^,c �' '.Sc� a^4 ,�. a ,�5+ -�.d ��a, ^." . SECTION 8 ATTACHMENTS Identify all supplemental information that is attached to the WCD,if any. Note the total number of supplemental pages attached. , _ 7 SECTION 9 ,;GENERATOR'S,CERTIFICATiONte�# The authorized representative of the generator identified in Section 1 (c)must sign the certification. The WCD will not be processed and the waste will not be approved for BFI management without completion of this and all other sections. ~ ®Waste ..� wCD 5 2 9 P L OSystems­ BROWNING-FERRIS INDUSTRIES BFI WASTE CODE WASTE APPROVAL REQUEST BFI to complete this area. BFI Initiator. Action Requested: ❑New Waste Approval Location: ❑Up-Date Approval - Previous Number: Company Number: Disposal Site Requested: Telephone:( ) Company Number: Fax:( ) Management Method Requested: ❑Landfill ❑Hauling Date: ❑Other 1NASTE CHARACTERIZATION DATA . .._ _ SPECIAL WASTE IMPORTANT.THIS FORM IS TO BE COMPLETED BY A REPRESENTATIVE OF THE WASTE GENERATOR.PLEASE READ THE INSTRUCTIONS BEFORE COMPLETING THIS FORM.THIS FORM IS TO BE USED ONLY ONE TIME,AND MUST BE TYPEWRITTEN OR LEGIBLY PRINTED IN INK,AND SIGNED. 1.GENERATOR INFORMATION a) Generator's Name: e)State/Provincial/Local Registration No.: b) Generating Facility's Address: Generator's EPA Id.No.: City: State: Zip: Industry Description/SIC Code: c) Generator's Representative: ' Title: f)Customer's Name: Telephone:( ) g)Customer's Mailing Address: Fax:( ) City: State: Zip: d) Emergency/Information Contact: h)Representative: Title: Telephone'( ) Telephone:( ) Fax:( ) 2 GENERAL',WASTE STREAM INFORMATION a)Name/Description of The Waste: b) Process Generating Waste: c)Is this a treatment residue of a waste which was previously a restricted hazardous waste? ❑Yes ❑No If yes,describe the waste and the process generating the waste prior to treatment. d)Is this a"Hazardous Waste"as defined by State,Provincial,or local Regulations? ❑Yes ❑No If yes,enter the Waste Identification Number if one has been assigned: e)Is this a"Special Waste",an"Industrial Process Waste",or a"Pollution Control Waste"as defined by State, Provincial,or local Regulations? ❑Yes ❑No If yes,enter Waste Identification Number: f)Recommended personal protection equipment and special handling procedures: g)Anticipated Volume: ❑Cubic Yards ❑Tons ❑Gallons ❑Cubic Meters ❑Tonnes(metric) Other Per: ❑Year ❑Month ❑Week ❑Day ❑One Time ❑Other To be transported in: ❑Buik ❑Drums(type/size) ❑Other h)Is a representative sample included? ❑Yes ❑No 3:`WASTE PROPERTIES AT 72 17 = a)Physical State: e)Density Range: to ❑Solid ❑Semi-solid ❑N/D ❑lbs/gal. ❑g./cc. ❑Powder ❑Liquid ❑lbs./yd.3 ❑Kg/m3 ❑Other ❑Combination b)Layers: f)Flash Point,°F: ❑Single-layered ❑Bi-layered ❑Multi-layered O<_72 ❑73-100 ❑101-140 c)Colors(s): ❑141-200 ❑>_201 ❑N/A ❑N/D Describe d)Odor: g)pH: Describe ❑ <2 ❑2.1 -5.0 ❑ 5.1 -9.0 0 None 0 Mild 0 Strong 0 9.1 -12.4 0>_12.5 0 N/A 0 N/D 4 BFI WASTE CODE 4: REACTIVITY' 5:THIS.WASTE CONTAINS &.SPECIAL WASTE COMPOSITION Note if the waste exhibits any of Note if the waste contains any of the following: Concentration ranges are suggested and units the following reactive properties If any are checked"Yes",specify type must be identified in percentages(%)and/or (if applicable)and include its concentration parts per million(ppm).Attach additional pages if O Water Reactive as part of the waste composition,Section 6. - necessary. 0 Acid Reactive `' . Range ❑Alkaline Reactive ❑ Free Liquids EI OSHA Substances Components Min./Max. CI Oxidizer ❑ Free Cyanide ❑Etiological Agents O Autopolymerizable 0 Free Sulfide ❑Pathogens " fD Pyrophoric -; ID Free Ammonia ❑Biological Materials ry fD Explosive 0 Dioxins ❑Radioactive Materials •Thermally Sensitive O Organic Solvents ❑PCBs not regulated O Shock Sensitive ❑Virgin Oils by TSCA 40 CFR 761 O None of the above ❑Used Oils 0 None of the Above 7.TRANSPORTATION INFORMATION If the waste is a DOT Hazardous Material,complete the following: Proper USDOT Shipping Name: USDOT Hazard Class: UN or NA Number: CERCLA Reportable Quantity: r s` 8.'SUPPLEMENTAL INFORMATION • None ❑ MSD Sheets ❑Analytical Data ❑ Chain of Custody ❑MemolLetter ❑Waste Composition • Other-describe: No.of Pages: 9.GENERATOR'S CERTIFICATION I hereby certify that the above and attached description is complete and accurate to the best of my knowledge and ability to determine,that no deliberate or willful omissions of composition or properties exist,that all known or suspected hazards have been disclosed,and that the waste is not a regulated hazardous waste by the USEPA,by an applicable State or Provincial authority,or by any applicable local authority,and does not contain PCBs regulated by TSCA(i.e.,40 CFR 761)or any Provincial authority. GENERATOR'S AUTHORIZED SIGNATORY as identified in Section 1 (c): DATE PRINT NAME SIGNATURE TITLE r, .;.,`".REPRESENTATIVESAMPLE CERTIFICATION This Section is to be completed by the person obtaining the sample of the above described waste. I certify that the sample for which analytical data was provided on the waste described above is representative of that waste and was collected and preserved in a manner consistent with accepted technical standards. Lab sample assigned to: (peel orf label) Collector's Name: Signature: Generator's Name: Company: Title: Waste Description: Telephone Number: ( } Date Collected: WCD No. AB Date Collected: = EXHIBIT B Waste No. Systems TM ; BROWNING-FERRIS INDUSTRIES NON-HAZARDOUS SPECIAL WASTE MANIFEST • Generator Name Generating Location Address Address Phone No. Phone No. I BFI Waste Code Containers Type Description of Waste Ouantity Units No. Type D- Drum ❑ m 11B -Carton - Bag I m T -Truck i F-1 P - Pounds Y -Yards ❑ m F-10-Other I hereby certify that the above named material does not contain free liquid as defined by 40 CFR Part 260.10 or any applicable state law, is not a hazardous waste as defined by 40 CFR Part 261 or any applicable state law, has been properly described, classified and packaged, and is in proper condition for transportation according to applicable regulations. Generator Authorized Agent Name Signature Shipment Date - TRANSPORTER Truck No. Phone No. Transporter Name Driver Name (Print) Address Vehicle License No./State Vehicle Certification I hereby certify that the above named material was picked up I hereby certify that the above named material was delivered with- at the generator site listed above, out incident to the destination listed below. Driver Signature Shipment Date Driver Signature Delivery Date t • Site Name Phone No. —ITT7 I Address I hereby certify that the above named material has been accepted and to the best of my knowledge the foregoing is true and accurate. Name of Authorized Agent Signature Receipt Date PASS CODE SF1260.720 3193 EXHIBIT C_ S'63NIv.LNC:):10 b38rtnN 1919 -h9tJ ! 4-1 0 Z W 0 (DUs QdID. OV31 W101 i z 9 a 0 LU LX6 U Im IS2 a. (U) S1V13 W INvimiod UlIi011id Z UO SIV13W WYD !N'UZ'qd'JD'P:):SlVigW S aa.�S d��. � 4 I ) • (L'BLV Vd3)SNOSZIVDObGkH 318"3AODU IY101 LU > e U') (0909,909 Vd3) te S300LIS34 jj C C (0809'9019 Vd3) rn et 0 G:)d C ( +3':i+8 'OZSS Vd3) asvuo 12 110 IvIol E cO 0 (m 10'as Lzglszg vd3) (3 sGov'sivx1n3N/3SVG C6 (Z'tts lotzg'vzg vd3) S:)INVDIJO 31UVIOA 0 if (OLOS*Log Vag) N, • SNOSVYDOIVH 3imovnd LU CD (OZOE ZO9 Vd3)X31S mywony neynani. -4. < 5 Lu r- z 2 CD M 0 (SLOB IOSSE/Otsc Vd3) uj F� 0 w 'ZI*51 1 Hdu'fasaia-HdI 0 (OZO21019 Vd3))ais/,K (S Log locos)aullosro-Hal 04 (SLOB locos Vd3) aulloseD HdI Vl- 0 0 �#N =0 < d 11 UJ -W EVA- L) 0 tj 0 ws z 10Cn 0 W% CD L) O O 2 LU 0 Im < CD CD N.7 E LU :z < 1V:U-0-WMHLHb lNk:. FRX NO'510-484-1096 #451 P02 CHROMALAB, INC. iErMronmeMl Service6(SDS) December 23 , 1994 Submlasion 9412247 BFI KELLER CANYON Atten. Kim O'Neal Project; . - :-. .- ...I Received: December 16, 1994 re: 1 sample for BTEX compounds analysis. Matrix: SOLID Sampled: December 16, 1.994 Run#: 4968 Analyzed: December 22, 1994 Method: EPA 8020 BY 8260 Ethyl Total Benzene Toluene Benzene Xylenes SP-1 # CLIENT SMYL ID "U /TICT) AUCTLNa) (wq/m) (ucr/-K-q) 73216 AB34993 N.D. 480 N.D. 670 Reporting Limits 250 250 250 250 Blank Result N.D. N.D. N.D. N.D. Blank Spike Result (t) r 97 83 Oleg Nemtsov Ali *Xharrazi Chemist Organic Manager 1220 Quarry Lane•Pleasanton, California 94566-4756 (610)484-1919-Facsimile(510) 484-1096 Federal 10#$8-0140157 15:54 11):frH UMHLHfj INC: FAX NU:510-484-1096 #451 POZ CHROMALAB, INC. Environmental Services(SOB) December 22, 1994 Submission 9412247 BFI KELLER CANYON Atten: Kim O'Neal Sampled: December 16, 1994 Submitted: December 16, 1994 Extracted: December 20, 1994 Analyzed: December 20, 1994 Project. Method: EPA 3580/8270 Project #: N/A Matrix: SOLID Cl i en t: Sample X-D: AB34993 Dilution Factor: 1:10000 Reporting Sample Limit COMP!aUND NAME Mg/kcT mcrZka PHENOL N.D. 500 BIS (2-CHLOROETHYL) ETHER N.D. 500 2-CHLOROPHENOL N-D. Soo 1, 3-DICHLOROBENZENE N.D. Soo 1,4-DICHLOROBENZENE N.D. Soo BENZYL ALCOHOL N.D. 1000 1,2-DICHLOROBENZENE N.D. 500 2-METHYLPHENOL N.D. Soo BIS(2-CHLOROISOPP-OPYL)ETHER N.D. 500 4-METHYLPHENOL N.D. Soo N-NITROSO-DI-M-PROPYLAMINE N.D. Soo HEXACHLOROETHANE N.1) Soo NITROBENZENE N.D. Soo ISOPHORONS N.D. 500 2-NITROP14ENOL N.D. Soo 214-Z)IMETHYLPHENOL N.D. Soo BENZOIC ACID N.D. 2500 SIS(2-CHLOROETROXY)METHANE N.D. Soo 2,4-DICHLOROPHENOT, N.D. 500 1, 2,4-TRICHLOROBENZVNE N.D. 500 N&PIrrHALENE N.D. 500 4-CIMORGANILINE N.D. 1000 HEXACHLOROBUTADIENE N.D. 500 4-CHLORO-3-METRYL.P'HENOL N.D. 1000 2-METHYLNAPHTHALENE N.D. Soo HEXACHLOROCYCLOPEMADIENE N.D. Soo 2,4, 6-TRICHLOROPHENOL N.D. Soo. 2,4, 5-TRICHLOROPHENOL N.D. 500 2-cHLoRoNA-PHTRALRNE N.D. Soo 2-NITROAXILINE N.D. 2500 DIMETHYL PHTHALATE N.D. Soo ACENAPHTHYLENE N.D. 500 3-NITROANILINE N.D. 2500 ACENAPHTHENE N.D. 500 2,4-DINITROPHENOL N.D. 2500 4-NITROPRENOL N.D. 2500 DIBENZOFURAN N.D. 500 (Continued on next page) 1220 Quarry Lane•Pleasanton,California 94666-4758 (510)484-1919 a F=sirnife(510)454-1096 Padoral ID#68-0140157 CHROM,ALAB, INC. Environmental Services(SOB) December 20, 199^ Submission #: 9412247 HFI KELLER CANYON Atten: Kim O'Neal Project: „ Received: -LAUatmber 16, 1994 re: One sample for reactivity, corrosivity, and ignitability (RCI) analyses. Matrix: SOIL Sampled: December 16, 1994 Analyzed: December 20, 1994 Method: CA Title 22 SEC.66261.21-23 Client Sample # Sample ID Reactivity Corrosivity IcMitability 73116 AB34993 No pH 8 .1 No Blank No pH 7.0 No ChromaLab, Inc. V Douse Ali a2i Organic Manager cc 1220 Quarry Lane•Pleasanton,Califomia 94566-4756 (510)484-1919•Facsimile(510) 484-1096 Federal ID#68-0140157 �-- —� --• .♦ l.�•JJ 1L•l.l uuiru-u aL. ('M/ IVIJ .:1lJ—µOH-1KJ7o Ma.Jl rJ-/ CHROMALAB, INC. Environmental Services(SDS) Page 2 Submission #: 9412247 Project.- Project roject:Project #: N/A Client Sample ID: AB34993 Method: EPA 3580/8270 Matrix: SOLID Reporting Sample Limit Spike COMPOUND NAME mg/ker mg/kg Recovery 2,4-DINITROTOLUENE N.D. 500 2, 6-DINITROTOLUENE N.D. 500 DIETHYL PHTHALATE N.D. 500 4-CHLORO-PHENYL PRENYL ETHER N.D. Soo FLUORENE N.D. 500 4-NITROANILINE N.D. 2500 4, 6-DINITRO-2-METHYL PHENOL N.D. 2500 N-NITROSODIPHENYLAMINE N.D. 500 4-BROMOPHENYL PHENYL ETHER N.D. 500 HEXACHLOROBENZENE N.D. 500 PENTACHLOROPHENOL N.D. 2500 PHENANTHRENE N.D-. Soo ANTHRACENE N.D. 500 DI-N-BUTYL PRTHALATE N.D. 500 FLUORANTHENE N.D. 500 PYRENE N.D. 500 BUTYLBENZYLPHTKALA,TE N.D. 500 3,3' -DICHLOROBFNZIDINE N.D. 1000 BENZO(A)ANTHRACENE N.D. Soo BIS (2-ETHYLHEXYL) PHTHALATE N.D. 500 CHRYSENE N.D. 500 DI-N-OCTYLPHTHALATE N.D. 500 BENZO(B) FLUORANTHENE N.D. 500 BENZO(K) FLUORANTHENE N.D. 500 BENZO(A) PYRENE N.D. Soo INDENO(1,2, 3 C,D) PYRENE N.D. 500 DIBENZO(A,H)ANTHRACENE N.D. 500 BENZO(G,H, 1) PERYLENE N.D. 500 ChromaLab, Inc. Alex Tam � Ali Kh razi Analytical Chemist Organic Manager 1220 Quarry Lane-Pleasanton, California 94565-4756 (510)484-1919• Facsimile (510)484-1096 Federal ID#68-0140157 JAN. -05' 95(THU) 09:57 CHRONIALAB, INC. TEL510 831 8798 P. 002 ,.�. GeoAnalytical Laboratories, Inc. 1405 Kansas Avenue,Suite A Phone(209)572-0900 Modesto,CA 95351 FAX(209)572-0916 CERTIFICATE OF ANALYSIS LC50 Report* F354-10 Date: 12/28/94 ChromaLab Date Received. 12/20/94 1220 Quarry Lane Date Started: 12/22/94 Pleasanton CA 94566 -4756 Date Completed: 12/26/94 Project# 9412.247 ProjectName: BFI Sample ID: A834993 Lab ID: P11940 Aquatic Toa dty Species: Pimephales Promelas Test Type: LC50 Common Name: Fathead Minnow Dilution Water. Reconstituted DI Water Supplier: Thomas Fish Farm Number per Tank: 20 Dead in Acclimation Tank: <1% Tank Volume: 10 Liters Average Length: 34 nvn Average Weight: 0A1 g Initial Control Hardness: 48 mg/L Final Control Hardness: 48 nig/L. Results/Notes: 1.Added 0.5m1 acetone to each sample to help dissolve organic portion.An additional control with 0.5ml acetone was observed in addition to the regular control. 2.There were no significant mortalities observed in this test.LC50>500mg/L. Page t of 2 'JAIN. -Ua 10�Inv) X17;J6 t,nKVIVEHLdD. IIYtr. !G>3•��41 7�1 or7a r VVO �kx GeoAnalytical Laboratories,. Inc. 1405 Kim=Avenue,Suitt A Phone(209)572-090t? Modesto,CA 95351 PAX(209)572-0916 MWICATE OF ANALYSIS Report#: F354-10 Sample ID: AB34993 Lab ID: F11940 Initial 12/22/94 rantrd ao1vLQW 250 MS& MnWA mg& 750 mgtL PH 7.65 7.18 7.28 7.36 7.36 7.42 7.50 D_{3_ 7.22 7.93 8.24 8.52 8.64 8.63 8.54 Temp 20' C 20'C 20' C 20' C 20' C 20' C 20' C 24 hrs 12/23/94 PH 7.16 7.20 7.21 7.25 7.23 7.25 7.25 D.O. 7.18 7.35 7.88 8.10 7.87 8.17 8.01 Temp 21' C 21, C 21, C 21' C 21, C 21, C 21' C Mortalities 0 0 0 0 0 0 0 48 hrs 12/24/94 PH 7.09 7.12 7.17 7.16 7.20 7.19 7.15 D.O. 6.74 6.$8 7.61 7.87 7.44 7.91 7.72 Temp 21' C 21'C 21'C 21' C 21' C 21' C 21' C Mortalities 0 0 0 0 0 0 0 72 hrs 12/25/94 pH 7.12 6.95 7.15 7.23 7.23 725 7.20 D.Q. 7.10 654 7.10 7.85 7.33 751 7.56 Ternp 22' C 22' C 22' C 22' C 22' C 22' C 22' C Mortalities 0 0 0 0 0 0 0 96 hrs 12/26/94 PH 7.36 7.32 7.42 7.40 7.39 7.37 7.39 D.O. 7S1 6.46 6.88 7.66 712 7.06 716 Temp 22' C 22' C 22' C 22' C 22' C 22' C 22' C Mortalities 0 0 0 0 0 1 0 Total Mortalities 0 0 0 0 0 1 0 raig ares Donna Allsup Bacteriological Dept. 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W C CIO 110, Cc p e} cry 4►) QO Cit t+1 a C"1 00 M •-+ +: 9Z R CRI �+ cat's ami+ cr, 0% t`�n ' cure+ d et er d 21 1 �r 1 O00 N M Q N 44 !"� t� 0\ cCh l ray N moi' V7 O ei �-+ t'd N Git d' ZI'i r et 4 tt; In C'; M ORi 01 t,?1 r�-r Qt GT+ Qt Clt t7t cr, at Ch + tit Ch 4T dt Ut amt tat at N04 te�+}I Ce�•�iy Q ;: 0 0 O 0 G7 a a a to a ST"d -lulol ,g sg . 1 G , 2 •� -14 av ,� ! tf 00 tf; N N fV 0-1 try tV .Cy c � o � c wcn tn M Ch 1�p cn c� N Npp cp% ,4d; � N N .p.a Np Cr1 M M M N . Ch O O Q O Q S O N �-+ M M C)% N h en C7, CIO if) ee�� 1� � c c�T Com+ t a Off► a v DO N .-4 ..a V-4 .-.+ LATE: l G• `'9<< REQUEST TO SPEAK FORM (THREE (3) MINUTE LIMIT) \ / Complete this form and place it in the box near the speakers' rostrum before addressing the Board. NA.yIE: � �if/I PHONE: �t ,5 ADDRESS: Aleajawl / a CITY: /✓G`GArGo , eio� I am speaking formyself OR organization: Check one: (NAME OF ORGANIZNTION) I wish to speak on Agenda Item # My comments will be: general for against I wish to speak on the subject of I do not wish to speak but leave these comments for the Board to consider. 5 ® Recycled paper Waste Systems- BROWNING-FERRIS INDUSTRIES Contra Costa County June 5, 1995 The Hon. Gayle Bishop, Chair and Members of the Board Contra Costa County Board of Supervisors 651 Pine Street Martinez, California 94553 Re: Keller Canyon Landfill; Agenda Item D.1;Report From Staff Regarding Keller Canyon Landfill Receipt of Special Waste Dear Chair Bishop and Members of the Board: I am writing you as a follow-up to the Board's May 23, 1995 discussion of Keller Canyon Landfill's receipt of special wastes. During your discussion on this item, some of the Board members asked questions concerning the facility's receipt of special waste from outside the County, as well as questions regarding review of analytical data and KCLC's contracts with its customers. We are happy to provide the following responses to the Board's questions. As a result of Supervisor DeSaulnier's request, we have agreed to voluntarily refrain from entering into any contracts with new customers for special wastes from outside the County for a period of sixty (60) days effective May 26, 1995. We spoke with Supervisor DeSaulnier on May 26 and informed him of this fact. In doing so, we want to make clear that the facility's permits authorize our taking this waste, and we have fully vested our rights to receive these wastes. We are making this 60 day commitment solely as a gesture of good faith to your honorable Board and the communities near the facility, to see that the public education effort to correct the misinformation that has circulated about the site and special wastes gets off to a good start. Board members also requested that we provide laboratory analytical information about the wastes received at the site. We have provided your staff with copies of analytical data, with client names and proprietary information redacted. As you may know, the Local Enforcement Agency (LEA) staff inspects the facility regularly, and as part of that inspection the LEA reviews the site analytical records for special wastes received. The analytical documentation demonstrates our compliance with Condition 4. of the Board's December 14, 1993 Order authorizing the facility to receive out-of-county special wastes, which requires that we document that proper analytical SOLID WASTE COLLECTION BFI TRANSFER KELLER CANYON AND RECYCLING DISTRICT • STATION AT MARTINEZ • SANITARY LANDFILL (510) 685-4716 (510) 313-8900 (510) 458-9800 441 N. BUCHANAN CIRCLE • PACHECO, CA 94553 • P.O. BOX 23164 • PLEASANT HILL, CA 94523 (510) 685-4716 9 FAX: (510) 685-4735 3 The Hon. Gayle Bishop and Members of the Board June 5, 1995 Page 2 information has been obtained prior to our receiving the wastes. Although this requirement technically applies only to the out-of-county special wastes, we have this documentation for all special waste received at the site regardless of origin, and your staff is of course able to review this material during inspections of the facility. Board members also asked about reviewing our special waste customer contracts. These contracts can be reviewed by your staff during facility inspections, but in the event you or your staff request copies we will need to remove all proprietary information, including customer names and pricing information, before they are forwarded to the County offices. These contracts do contain information regarding our customers and business arrangements that would be highly valuable to our competitors, and for this reason we must remove this confidential and proprietary information. If you or your staff do request copies, we can provide redacted copies of these contracts within approximately one week of receiving the request. Finally, Supervisor Smith asked about our utilizing contaminated soils which have been incinerated or otherwise thermally treated as daily cover at the site. Since we have withdrawn our request to implement an Alternative Daily Cover(ADC) program at the facility, we expect that all daily cover material will come from excavated on-site sources. We would therefore not have a need to use thermally treated soils on-site,-nor do we have any plans to implement any incinerator or thermal treatment unit at the facility. I hope the foregoing has responded to the questions asked at the May 23, 1995 meeting. Very truly yours, Ken Etherington KE.jcf cc: Victor J. Westman, County Counsel Rebecca Ng, CCC LEA Dennis P. Fenton, BFI Michael Caprio, BFI Scott W. Gordon, Bruen& Gordon JUN-06-1995 08:55 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.01 FAX TRANSMITTAL City of Pittsburg FROM THE OFFICE _. OF THE CITY MANAGER 3� DATE: FAX NUMBER: L," 1 C�`_��f NUMBER OF F A OES: (Including this page) COMMENTS: 7N z .I FROM: V� '��. , P. O. Box 1518 Pittsburg, California 94565 PHONE # 510 439 4850 FAX # 510-439-4851 if there are problems with this transrmttal, call 510-439-4850. JUN-06-1995 08:55 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.02 C- ity of Pittsburg Civic Center • P.03ox 1518 • Pittsburg,California 94565 OFFICE OF THE CITY MANAGER June 5, 1995 Mr. Val Alexeeff, Director Growl.lh 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 sut*t 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. INFORhLATION REQUESTS TO COUNTY STAFF One of the actions taken by the Board of Supervisors at its May 16, 1995, public hearing regarding Keller Canyon Landfill's receipt of non-municipal solid waste (Agenda Item HA) was to direct staff to make available all records and corresponding test data for each load of "s vial" acid 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 cord clearly indicates: 1) 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 (Attachment 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/fu=s, polynuclear aromatics, and soluble salts. R JUN-06-1995 08:56 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.03 Val Alcxccff Contra Costa County GMEDA June 5. 1995 Page Two Thcreforc, 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 Sumittary 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 Ew4rvnmental Research Corporation.. Guide to Oil Wctcre Manngement Alternatives, pp. 413-4.15.] 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 f6und, at what. concentrations. 1ENT DATA Rih;QU1K.lV MENTS tf the test data that you provide regarding contaminated -oil 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 contaminants 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 providing us with one of the following.: 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. ti JUN-06-1995 08:57 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.04 Val Alcxccff 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 C1WMB'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 xsmime 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 we consider receipt of this document critical the f rthnnming Planning Commie-don review of the LUP. SUMMARY V1AKY Ulh' KN:(?UESTED INFORMADON 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 tesi results. 1 JUN-06-1995 09:57 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.05 Val Alexceff 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 thez�e 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 tegulatory 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 suit IandfUled 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 CON01LISSION CONSIDERATION When the County Flaming 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 connrrdssion cines not find this desiTahle nr 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 Hble.. to cietesrmine. 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 Summary Findings and Report For Sludge, Ash, and Contaminated Soil: Appropriate Level of Regulatory Control Project (fourth draft, April 199.5), irdicatec that contaminants and toxin~ that may be found in sewage sludgelbiosolids JUN-06-1995 08:58 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.06 VEIL Atcxccff Contra Costa County GMEDA June 5, 1995 Page Five will vary depending on the treatment plant's influent, as well as treatment process, 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 planting 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 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- typP lsndfillpAl 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 indicatert in the attached new%paper clipping, Lah saye it.faLsified pollution test results, it is no unheard of for laboratories to falsify test results (Attachment Q. 1 JUN-06-1995 08:59 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.07 Val Alexeeff Contra Costa County GMEDA June 5, 1995 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 Platuting 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 Cos-ta Times article "Lab says it falsified pollution tests results" cc: Dan Guerra, Deputy Director Environmental Health Division R JUN-06-1995 08:59 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.09 4 Q: T. Civic Center • P.O. Box 1518 Pittsburg.• California 94565 r a �3 Irlew r lot, (n j 17y _W OFFICE OF THE, MAYOR May 23, 1995 The Honorable Gayle Bishop, Chair Contra Costa County Board of Supervisors 651 Pine Street Martinez, California 94553 RE: BION-MUNICIPAI, SOLID WASTE DISPOSAL AT KEI LER CANYON LANDFILL Dear Supervisor Bishop: L, dais tnarning's edition of the Contra Costa Times we read a quote from you that, "Very_ clearly special wAstes are not hypodermic needles, not PCBs not hazardous materials." In light of the attached LEA Advisory, as well as the fact that contaminated soil falls within one or more of your staff's 10 different definitions of special and designated waste, we must respectfully point out that your comments are in error. Keller Canyon Landfill's receipt of contaminated soil is well documented by County staff and is not contested by representatives of the landfill. The attached LEA Advisory, which pertauis to the use or c omamiuAt,etl avil as daily cover and was specifically referenced by BFI in its recent application for this change in operations, clearly states that contaminated soils can contain much more than petroleum by-products: 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 dioxinsffurans polvnuclear aromaggs,and soluble salts These contaminants, if present, may pose threats to water quality and/or to workers at the landfill. We realize that you rely on staff information in considering issues of this importance, and it is regrettable that the information you receive from staff is not always factual. Hopefully, the attached document will help you better understand tie concerns of those of us that live in the shadow and winds of Keller Canyon Landfill. Sincerely, doe �^IrPIP Taylor Davis Mayor cc: Pittsburg City Council JUN-06-1995 09:00 FROM CITY OF PITTSBURG MANAGER TO 96461059 P,09 fine r itsun No. 5 December 15, 1993 tOnew ■1l�AlL XXXIM man IN'rn=GRATeD . USE of NON-HAZARDOUS 1rtANACZM�N'r GF 1)OA&D CONTAMINATED SOIL As DAILY COVER To All Local Enforcement Agencies Mature of Contaminated Sols rnntaminated soils (CS) may include soils contantivated with petroleum hydrocarbons anti/or heavy metals. Heavy metal contain ination of soil is generally a result of discharges to soil of chemicals and/or wastes that contain heavy metals. Soils contaminated with petroleum hydrocacUutla (&rived from petroleum products) are convnonly referred to as fuel contaminated soils (FCS). FCSs are formed by tate uncontroiled release of gasoline, diesel, heating oil, waste oil. kerosene and other petroleum-based Hydrocarbons from undergrnt,nd and aboveground storagt; tanks, or cumulative spills in and around equipment maintenance and repair yards. Leaking or spilled fuel contaminates tate surrounding soil and in many instances the underlying ground water. Contaminated soils trust be classifiers as "non-hazardous" per Title 22, Cal;rUrnin Cade of Regulations criteria in order to be accepted at Class 11 or 211 landfills. Sources of Contgminated Suils Contaminated soils result from two main activities: (1) large quantities are from tho innurmcrablc piles of contaminated soil excavated with the removal of leaking fuel storage tanks, and (2) from remediation praiects at hazardous waste sites, including illegal disposal sites, railroad yards, federal acid state facilities. and sl)ills of hazardous materials/waatc resulting rrtrm transportation accidents. Use of Contaminatgs Soils as aiiy Ctrver Staff of the California Integrated Waste Management Board believe that contaminated suits, at levels allowed under current Waste Discharge Requirements (WDR) issued by the Regional Watcr Quality Control Boards and permits issued by the local Air Quality Management Districts, would behave similarly to clean soils with respect to the ptopr-,rties necessary to satisfy current daily cover requirements. At its November 17, 1993 Treeting, the Board considcrcd an krait concerning tht use of Contaminated Soil as Daily Cover. The Board concurred in the following policies .relating to Olt- use of clean and/or contaminated soil as daily cover: I. The use of non-Hazardous contaminated soil as daily cover clues not require a demonstration project pursuant to the Board's Alternative Daily Cover Policy of 1990. JUN-06-1995 09:01 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.10 2. Sail (duan or c:ontamivated) used as.daily-rover will noetbetbzluded-*h)tltelperrnhited,-,, fl .rete. daily tontlage of the facility. {. Soil (clean or cu,ctamiaatcd} used as-daily c:uver..w,liljtiotibeLW4j=J0;kbe IandflIf4isposal :;::; .:..,� . 4. The use of non-Hazardous C4lntamivated soil a .daily- icoxer:rnust meet:W1iregttir d,-,.Air\and,i-,1 me(- Water Board rules and regulations. reg1.;s:tio';. Reuittnal Water Quality Cwltxti3"Brig l:Itequrt�etrients _c ` !3c;:tci ';amu` em��:� Waste Djsclvtnp; Requirejnant�,*r isWed.for-oath facility wheic.0S.is,. Obred4stre tted;tciisposed of used as(-;. - :eatt. daily co)%r. The. WDRs for sifts whioh receive CS'establish''the tiiWnnun3 ilsv6),%tpetr6l6um hydrocarbon�or' heavy ictal concentrations for CS that the site is permitted to accept. For Class III landfills, soils mast not be "des4piatc:d wastes" per State acid Regional Water Board regulations:and.�rbeedures-. . Cotttattliltants other than acetals and petroleum hydrocarbons may nrcasibnall}► W present in "contaminated soils", depending on the source,of the soil. Other contaminants of concern include- solvents, pesticides, PC13s, dioxins/furans, polyttucldai aroiitat.ics, and soluble salts. Thesexbntatnina.nts, if present, may pose threats to water quality and/or 1e"avorkers at th*.lah fill. if presenC't€c::,.;EAishoutd,monitor-records at the facility to ensure that such cotltadlillants are below levels required by regulations or permits. Condit;on of At pr-,)vai L Sites accepting cotttattlrttated soils for use as-daily cover, treatment orsdisposal-must-maintain-write, r proi;ecdures for screening wastes and on-site records pf analytical test results for contaminated soils accepted, including descriptions of the source(s) and nature of contamination. If the LEA finds that an operator ha. inadcyuate recor&.or has reason to believe that wastes are.being improperly handled or accepter at the: facility,.the LLA may require pts-acceptance'review and approval through permit Wrlditions or an enforcement action before waste is accepted ori=site. 2. As clic LEA, you need'io monitor the records maintained by the operator pertaining to the acceptance of cuut.u;iin1ted suits fur use as daily cover for compliance with the above cnridition. Your authority in twsNrea acid aoy actions you take arises from the same statutes and regulations establishing your power as LLA (11RC Division 30, commencing with Section 40000,.and 14 C(: t,.Division F cutniamcm;ing, with.Stiction 17020). 3. The use: of tion-huzardous contaminated soil as daily cover.is an activity that needs to be reflected 'in the solid waste facilities permit. This can be auomyl)lisltcd with an amended RUSI and modified permit. Sites which have received CS in the past may continue.to ftceive such soils in accordance with the provisions of this Advisory until the permit is modified, Please now that the alcove conditions are not intended to limit the LEA- frorri-exercising its authority under federal, state, or lu:;al law to impose additional or more stringent requirements on landfills that utilize contain ilia Icd suits as daily cover. JUN-06-1995 09:02 FROM CITY OF PITTSBURG MANAGER TO 96461059 P-11 It you have any questions or need additional information, please contact your Permits Branch representative. Sincerely, ti P Don nierJr., .E ;- ., Manager Permits Branch, Permitting and Enforcoment Divibivii For back copies of the LEA Advisory contact the LEA Branch at (916) 255-2287. (LEA, Advisory #1, Oct. 6, 1992, Asbestos Containing Waste Disposal) (LEA Advisory#2, Feb.17, 1993, 1992 Legislation Impacts Existing Waste Programs) (LEA Advisory #3, June 1.0, 1993, Site Investigation Process for Investigating Closed, Illegal, and Abandoned Disposal Sites) (LEA Advisor),#4, Sept. 23, 1993, Permitting of Fucl rnntAininated Soils Troatrnent/ProccssinS 17ac!IWci;) N � 1 it-is o ailklopt R It vai r ' TIM L is M r r �{ �+�� � M �" •LT ♦ o'+tet' "a.G E+,s��i $ a'm ••''L� ii��K �rTOO C J .fit � ....�'..�.+^• '�� � � 1' A M Q is M+ '~ ��• C r �� Kia � � � • � -� 4. -� N �, , .,t ••r ra 9' g , �+ tit rot . �° - tn., JUN-06-1995 09:03 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.13 IIT „M4 FOURTH DRAFT (Incorporation of Public Comments) Summary Findings and Report For Sludge, Ash, and Contaminated Soil Appropriate Level of Regulatory Control Project April 1995 JUN-06-1995 09:04 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.14 INTRODUCTION SUMMARY OF REGULATORY OVERSIGHT United States Environmental Protection Agency California State Water Resources Control Board/Regional Water Quality Control Board Local Implementing Agencies California Integrated Waste Management Board Local Enforcement Agency Air Resources Board Air Pollution Control Districts/Air Quality Management Districts Department of Toxic Substances Control Occupational Safety and Health Administration California Occupational Safety and Health Administration California Department of Health Services County/C;cty Health Departments County/City Environmental Health Agencies County/City Planning Departments/Commissions California Department of Food and Agriculture County Agricultural Commissioners Sewage Sludge Generators and Processors MATERIALS 1 SLUDGE Li .Definition i.ii Sewage Sludge Quality/Characteristics l.iii I Candling Methods, Environmental Impacts, and Regulations I.iii.a Incineration for Volume Reduction I.iii.b Land Application l.iii.c Land Disposal l.iii.d On-Site Disposal Tables Summary of Statutes and Regulations 11 ASH ll.i Definition Ilii Ash Quality/Characteristics Il.ii.a Municipal Waste Ash Il.ii.b Medical WA.."o Ash Il.ii.c Biomass Ash Il.ii.d Coal Ash ll.ii.e Sludge Ash , ll.ii.f Tire Ash Il.iii Handling Methods, Environmental Impacts, and Regulations Il.iii.a Land Application ll.iii.b Disposal Il.iii.c Manufacturing/Feedstock Tables Summary of Statutes and Regulations Ili PETROLEUM CONTAMINATED SOiL Illi Definition Ill.ii Contaminated Soil Characteristics ill.iii Handling Methods of Contaminated Soils, Environmental Impacts, and Regulations i ll.iii.a Treatment ill.iii.b Manufacturing/Feedstock Table Summary of Statutes and RPgulations �fATf�l� JUN-06-1995 09:04 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.15 Fourth DRAFT April 1995 Summary Findings and Report Page 3 INTRODUCTION Current California Integrated Waste Management Board (CIWMB) regulation of solid waste operaVons is geared to traditional facilities (e.g.,landfiils and transfer stations), and does not easily translate to the unusual nature of nontraditional operations. For this reason, the CIWMB initiated an effort to determine the CIWMB's level of regulatory control for nontraditional solid waste operations, the Appropriate Level of Regulatory Control (ALRC) project. Examples of these operations include; sewage sludge landspreading, tro atment of contaminated soil, cement kilns using municipal solid waste (MSW), and the incorporation of ash as a soil amendment. Applying CIWMB regulation to these nontraditional operations has resulted in confusion among the regulated community and Local ;nforcement Agencies (LEA), orcating uneven application of statutory and regulatory requirements throughout the state. The ALRC project consists of the following goals. a to identify broad categories of material types handled by nontraditional operations; a to examine the environmental, public health, welfare, and safety aspects of the material types and their nontraditional handling methods; a to evaluate the level of existing regulations for the material types and associated handling methods; and 9 to recommend the appropriate level of regulation by the CIWMB for these nontraditional nporations. To address these goals, CIWMB staff narrowed the initial focus of the project to sludge, ash, and contaminated soils. This was based on a CIWMB survey of LEAs to determine which nontraditional operations posed the greatest concern statewide. CIWMB staff researched these priority materials and their associated handling methods, and identified environmental impacts dr►d axiating regulatory oversight for each handling method. The information was compiled into a draft report and distributed to the public for comment. The CIWMB also solicited comments from local, State, and Federal agencies, and public and private entities through several public workshops held statewide. Comments fell into one of two categories: 1. comments on the information contained in the report, and 2. comments regarding the appropriate level of regulatory control. This report contains edits that were suggested during the public comment period and later from Stats agPnrips. It does not include recommendations for the appropriate level of regulatory control. The CIWMB will use the information contained in this report as well as public comments in making its assessment of the CIWMB's level of regulatory oversight. SUMMARY OF REGULATORY OVERSIGHT United States Environmental Protection Agency (USEPA) USEPA is the Federal agency responsible for enforcing Federal environmental laws, including the Clean Air Act, Clean Water Act, and-the Resource Conservation and Recovery Act (RCRA). USEPA developed the Federal sewage sludge regulations and is currently the permitting authority for the standards contained in 40 of the Code of Federal Regulations (CFR) Part 503. JUN-06-1995 09:05 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.16 Fourth DRAFT April 1995 Summary Findings and Report Page 4 California State Water Resources Control Board (SWRCB)/Regional Water Quality Control Board (RWQCB) The SWRCB and the nine RWQCBs are the State's lead agencies for the control of water quality under the Porter-Cologne Water Quality Control Act [codified as Division 7, commencing with Section 13000 of the Water Code (WC)1. The Water Code specifically roquiroc the SWRCS to develop waste classification and containment requirements for waste disposal sites (including liquid and hazardous wastes). The SWRCB adopted those regulations as Title 23 of the California Code of Regulations (CCR) Section 2510 at seq. TI it! SWRCB oversees and supports RWQCB implementation of, by agreement with USEPA, the Federal Clean Water Act [National Pollutant Discharge Elimination System (NPDES) program and Non-Point Source program, Including abandoned mines] and the water quality aspects of the Federal Solid Waste Disposal Act, as amended by the RCRA Subtitle D regulations for municipal solid waste landfills and RCRA Subtitle I underground tanks program, with an application.for program approval pending. SWRCB - The SWRCB is responsible for statewide water quality control and also administers the State's water rights program. The SWRCB is a five-member board with an Executive Director (ED), and staff who report to the ED. The SWRCB is authorized to promulgate whatever rules and regulations are needed to implement its statutory responsibilities, and is directed to adopt State Policy for Water Quality Control, and may adopt Water Quality Control Plans. Such regulations and policies are binding on all State agencies. The SWRCB also reviews actions of the RWQCBs either at the request of aggrieved persons or at its own discretion. RWQCBs - The nine RWQCBs are directly responsible for implementing the WC and rules, regulations, policies and plans promulgated by the SWRCB in regulating water quality within their respective watershed regions. The RWQCBs consist of nine part-time members with an Executive Officer (ED), and staff who report to the ED. The RWQCBs adopt regional Water Quality Control Plans that set out beneficial uses of waters within the region and establish water quality objectives needed to maintain these beneficial uses. RWQCBs issue waste discharge requirements (WOR) for individual discharges of waste that could affect the quality of the waters of the state, including discharges of waste to land. The RWQCBs inspect sites, review technical and monitoring reports, require corrective action when discharges pollute [or threaten to pollute] waters of the state, and issue a variety of Board orders to enforce the WC or provisions of WDRs or other Board orders. Underground Storage Tank Local Implementing Agencies (LIAULocal Oversight Program Agonoioc 1LOP) LIAs are local agencies, usually county or municipal health departments that implement SWRCB regulations for permitting underground storage tanks. A few LIAs and the 21 local agencies in the LOP oversee underground tank cleanups. The LOP agencies are local agencies, usually county or municipal health departments, which are under an annual contract to the SWRCB to implement underground tank cleanups under their respective jurisdictions, and implementing the SWRCB regulations and policies. Where no local agency oversees site cleanup, the RWQCB acts as the lead agency for cleanup oversight. California Integrated Waste Management Board (CIWMB) The CIWMB is the policy-making body responsible for the oversight of nonhazardous solid waste laws in the state. The CIWMB is a six-member board with an Executive Director (ED), and staff who report to the ED. The CIWMB is responsible for overseeing the local implementation of the California integrated Waste Management Act (Act) of 1989. The CIWMB is charged with reducing the quantity of waste going to landfills and ensuring the local enforcement of State solid waste standards for the protection of public health, safety, and the environment. JUN-06-1995 09:06 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.17 Fourth DRAFT April 1995 Summary Findings and Report Page 5 To ensure protection of public health, safety, and the environment, the CIWMB reviews applications for solid waste facility operating permits, submitted by local enforcement agencies (LEA), and recommends for or against concurrence in the issuance of permits. The CIWMB also certifies LEAs to carry out solid waste management in its jurisdiction as an agent of the State. The CIWMB conducts studies and investigations of new or improved methods Mf solid waste handling, disposal, or reclamation; as well as coordinates development of city/county source reduction and recycling plans. Local Enforcement Agency (LEA) LEAs are a local authority, typically county or municipal health departments, that are certified by the CIWMD. Cach certified LEA is then authorized to carry out the mandates of the Publiu Resource Code (PRC) and state regulations (14 CCR, Division 7) in its jurisdiction. LEAs also enforce local ordinances adopted pursuant to statutes and regulations pertaining to solid waste. LEAs are responsible for reviewing proposed applications for solid waste facilities permit, and issuing or denying the issuance of the permit. They inspect and investigate solid waste collection, handling, storage, solid waste facilities and disposal sites and equipment for compliance with state and local standards. Air Resources Board (ARB) The ARB is the policy and oversight body appointed to preserve and improve the air quality of the state. The ARB is a nine member part-time board with an executive officer (EO), and staff who report to the EO, The ARB is responsible for development of policies, model rules, su9gested control measures, test methods, and new source review of nonattainment areas for the ambient air quality of the state. The ARB also evaluates the toxicity of noneriteria air contaminants for listing as a Toxic Air Contaminant. The ARB work2 with local air pollution control districts (APCD) to implement measures as needed to achieve and maintain state and federal ambient air quality standards. Air Pollution Control Districts (APCD/Air Quality Management Districts (AQMD) The Health and Safety Code (HSC) provides authority for the establishment of APCDs and AQMDs. These {ocal agencies are responsible for developing clean air plans and for adopting and enforcing regulations to control stationary sources, such as factories, power plants, incinerators, disposal sites, water treatment facilities, etc. The APCDs and AQMDs also issue Permits to Construct and Permits to Operate and monitor emissions from stationary sources. The local districts are autonomous in nature and operate with independent authority in addition to State and Federal authority. Department of Toxic Substances Control (DTSC) The DTSC is responsible for protecting and enhancing public health and the environment by regulating the management of hazardous.waste and promoting its reduction In the state, It is the lead agency responsible for the classification or declassification of hazardous wastes. in addition, the DTSC is reaspunatiblu fur prurnutirrg the following hazardous waste management hierarchy: reduction of hazardous waste generation, recycling, treatment, and land disposal. DTSC is headed by a director with staff located at a headquarters and four regional offices. Occupational Safety and Health Administration OSHA) The OSHA is the Federal agency with the authority, among other things, to: promulgate health standards; conduct inspections and investigations, and issue citations; require employees to keep records of safety and health data; petition the courts to restrain imminent danger situations; and approve or reject state program plans. Fourth KRAFT April 1995 Summary Findings and Report Page 6 California Occupational Safety and Health Administration (Cal/OSHA) The Federal Occupational Safety and Health Act of 1970 permits a state to manage its own occupational safety and health program. California is one of several states that does so. The program is administered by the California Department of industrial Relations, Division of Occupational Safety and Health. California Department of Health Services (DHS) The DHS is responsible for policy and regulatiwis dt►vaiopment relating to preventative medical services, public water supplies, environmental health, epidemiological studies, and public health. The DHS developed the "Manual of Good Practice for Landspreading of Sewage Sludge" in 1983, which was used to determine sewage sludge land application rates prior to the development of 40 CFR 503. County/City Health Departments Under the direction of a full-time health officer, health departments provide the following basic services: collection, tabulation, and analysis of public health statistics; health education programs; communicable disease control; medical, nursing, educational, and other services to promote maternal and child health; environmental health and sanitation services and programs; laboratory services; services in nutrition; services in chronic disease; snorviccs directed to the social factors affecting health; services in occupational health to promote the health of employed persons and a healthful work environment; appropriate services in the field of fancily planning; and public health nursing services. County/City Environmental Heatth Agencies Under the direction of the Director of Environmental Health, environmental health and sanitation agencies provide services and programs for the following: food; housing and institutions; radiological health; land development and uses; milk and dairy products; occupational health; water-oriented recreation; safety; vector control; waste management; water supply; additional environmentally-related services and programs as required by the County Board of Supervisors, City Council, or Health District Board; and air sanitation. County/City Planning Departments/Commissions Local government, typically throtigh a planning department or commission, Is responsible for issuing land use approvals for the permitting of any use of land, including solid waste facilities. Planning Departments*are often identified as the Lead Agency under the California Snvironmental Quality /pct (CEQA). Lead Agencioc arc rcaponsibie for carrying out or approving a project which may have a significant effect upon the environment. California Department of Food wid Agriuulture (CDFA) CDFA is responsible for regulating California's food-industry. This includes governing weights and measures enforcement, assessment of environmental hazards for agricultural chemicals and other pollutants, control and eradication of weeds and insects, meat and poultry inspection, animal health services, and laboratory services for agriculture. Agricultural products derived from sewage sludge are regulated as a fertilizer by CDFA under the Fertilizing Materials Law. Current policy is to license manufacturers or distributors, register labels of products that are packaged, and enforce labeling requirements for bulk distribution under Sections 14591 and 14631 of the Fertilizing Materials Law. County Agricultural Commissioners County Agricultural Commissioners are local airthoritiag that provide direct ovomicght of the following.agricultural activities: pesticide use on crops, agricultural burning, pollination, and import and export of fruits and vegetables. Commissioners maintain an Inventory of growers within the counties, collect agricultural statistics on crop production, and oversee the weights JUN-06-1995 09:07 FROM CITY OF PITTSBURG MANAGER TO 96461059 P.18 Fourth DRAFT April 1995 Summary Findings and Report Page 6 California Occupational Safety and Health Administration (Cal/OSHA) The Federal Occupational Safety and Health Act of 1970 permits a state to manage its own occupational safety and health program. California is one of several states that does so. The program is administered by the California Department of Industrial Relations, Division of Occupational Safety and Health. California Department of Health Services (DHS) The DHS is responsible for policy and regulativils development relating to preventative medical services, public water supplies, environmental health, epidemiological studies, and public health. The DHS developed the "Manual of Good Practice for Landspreading of Sewage Sludge" in 1983, which was used to determine sewage sludge land application rates prior to the development of 40 CFR 503. County/City Health Departments Under the direction of a full-time health officer, health departments provide the following basic services: collection, tabulation, and analysis of public health statistics; health education programs; communicable disease control; medical, nursing, educational, and other services to promote maternal and child health; environmental health and sanitation services and programs; IAboratory services; services in nutrition; services in chronic disease; cervices directed to the social factors affecting health; services in occupational health to promote the health of employed persons and a healthful work environment; appropriate services in the field of family planning; and public health nursing services. County/City Environmental Health Agencies Under the direction of the Director of Environmental Health, environmental health and sanitation agencies provide services and programs for the following: food; housing and institutions; radiological health; land development and uses; milk and dairy products; occupational health; water-oriented recreation; safety; vector control; waste management; water supply; additional environmentally-related services and programs as required by the County Board of Supervisors, City Council, or Health District Board; and air sanitation. County/City Planning Departments/Commissions Local government, typinntly thrmogh a planning department or commission, Is responsible for issuing land use approvals for the permitting of any use of land, including solid waste facilities. Planning Departmenis'are often identified as the Lead Agency under the California Environmental Quality /pct (CEQA). Lead Agencies arc responsible for carrying out or approving a project which may have a significant effect upon the environment. California Departniern of Food avid Agriuulture (CDFA) CDFA is responsible for regulating California's food.industry. This includes governing weights and measures enforcement, assessment of environmental hazards for agricultural chemicals and other pollutants, control and eradication of weeds and insects, meat and poultry inspection, animal health services, and laboratory services for agriculture. Agricultural products derived from sewage sludge are regulated as a fertilizer by CDFA under the Fertilizing Materials Law. Current policy is to license manufacturers or distributors, register labels of products that are packaged, and enforce labeling requirements for bulk distribution under Sections 14591 and 14631 of the Fertilizing Materials Law. County Agricultural Commissioners County Agricultural Commissioners are Incal authorities that provide direct nvarnight of thR following agricultural activities: pesticide use on crops, agricultural burning, pollination, and .w...►r.� ..-J ..t r-J ..r.r�..Ll�� /'+-��..r.r-�.� ...�.r�r.� �� .�..r..��... .t �.r.•.r.r Fourth DRAFT April 1995 Summary Findings and Report Page 7 and measures programs in all but five counties. They are also responsible for the inspection of eggs, weed control, rodent control, crop disaster relief, and regulating pest control businesses. Commissioners are contacted when sewage sludge is being applied on agricultural lands, but otherwise play no role. Sewage Sludge Generators and Processors Under the Federal Standards For the Use or Disposal of Sewage Sludge (40 CFR Part 503), the .generators of sewage sludge, wastewater treatment plants, and the processors of sludgc, such as composters, are required to meet the criteria set forth in 40 CFR Part 503 and monitor and report operational requirements and sludge quality. The Federal regulations allow for the standards to be self-implementing under the conditions that the permitting authority (currently USEPA) chooses not to issue permits and actively regulate standards. Under these conditions, the generator has the responsibility to ensure sludge quality and may, in some cases, collect reports and monitoring information from sludge processors and land appliers. MATERIALS I -SLUDGE IJ Definition For purposes of this report, "sewage sludge" means residual solids and RPmi-Aoiids resulting from the treatment of wastewater, but does not include wastewater effluent discharged from such treatment process. Sewage sludge includes materials derived from sludge, but does not include ash generated during the firing of towage sludge in a cowago sludgc incinerator, or grit and screenings generated during the preliminary treatment of domestic sewage. Tiia fermi "Liusulws" is a eytivriyrrl fur srwage sludge used by many industries Involved with sewage sludge generation, processing, and marketing. This term has not, as of yet, been incorporated into State regulations. As such, the term "sewage sludge" will be used in this document when reterring to or defining this material. It should be noted for purposes of this discussion that "solid waste" means all putrescible and nonputrescible. solid, semisolid, and liquid wastes, including the following: garbage; trash; refuse; paper; rubbish; ashes; industrial wastes; demolition and construction wastes; abandoned vehicles, and parts thereof; discarded home and industrial appliances; dewRtarod. trantarl. or chemically fixed sewage sludoe which is not hazardous waste; manure; vegetable or animal solid or semisolid wastes; and other discarded solid and semisolid wastes (PRC Section 40191). It should also be noted that materials derived from cowagc sludge, such as processed or composted sludge, but not including ash generated during the firing of sewage sludge or grit and screening generated during the preliminary treatment of domestic sewage, will fall under the saint rayulatory scrutiny as whole sewage sludge. (.ii Sewage Sludoe Quality/Characteristics Sewage sludge is the by-product of wastewater treatment. Dependent on the type of wastewater treatment plant or processes involved, sewage sludge can be generated during the primary, secondary or advanced stages of wastewater treatment. The sewage sludge generated during primary treatment is a result of physical settling and generally contains between three and seven percent solids which can be increased through thickening or dewatering. Secondary treatment involves biological processes, such as activated sludge treatment or trickling filters, and the resulting sludge is generally low in solids content {less than two percent). Advanced treatment processes involve additional filtration or chemical precipitation. Depending on the process used, the resulting sewage sludge may have chemicals added to it as part of the Fourth DRAFT April 1995 Summary Findings and Report Page 8 precipitation process, such as lime, polymers, or aluminum salts. Any of the sewage sludges discussed can be further treated through thickening, dewatering, digestion, conditioning, stabilizing, composting, or drying, to atter the physical attributes and properties of the sludge. .Sewage aludge convicts of water, dissolvod solids, and suspended solids removed from wastewater during the treatment process. Sewage sludge solids contain plant nutrients, trace metals, organic chemicals, and inert solids, many of which are cambined with c;VVIIWldx 01yailic cornWuunds'. Domestic sewage sludge, which is the focus of this report, is a result of the treatment of wastewater originating trom domestic, commercial, and industrial sources. Wastewater is considered domestic, according to USEPA, when any contribution to the total flow is from domestic sources. It is therefore possible that domestic sewage sludge could result from wastewater with a large industrial contribution. As a result, industrial pretreatment programs are necessary to minimize contaminants, such as metals, organic chemicals, and cyanide, contributed from industrial sources. Sewage sludge can be beneficially used when applied to land for its fertilizer properties. Sewage sludge is a low-analysis fertilizer with its primary nutrients including nitrogen, phosphorus, and calcium. Other nutrients include copper, calcium, magnesium, and sulfur. Although sewage sludge can act as a valuable... Suume, of nutrients rut plants, tha concentrations did signitiudnily lower than those found in most commercial fertilizers. The nutrient content and concentration in the sewage sludge would of course vary dependent on the source of the wastewater and treatment processes involved7. Liii Handling Methods, Environmental lmnaats,and Regulations Four primary methods used for handling sewage sludge, as defined by the USEPA, are considered in this report, incineration for volume reduction; land application; land disposal; and on-site disposal. Disposal into landfills, other than monofills, is not addressed in this report. There are ten key agencies responsible for oversight of sewage sludge management: 0 US Environmental Protection Agency; ■ California State Water Resources Control Board/Regional Water Quality Control Boards; ■ California integrated Waste Management Board; a Local Enforcement Agencies; a Air Resources Board; n Air Pollution Control/Quality Management Districts; ■ California Department of Health Services; ■ California Department of Food and Agriculture; a County Health/Environmental Health Departments; and ■ County/City Planning Departments/Commissions. In addition, there is oversight of sewage sludge management practices, to varyinb degrees, by local enforcement, health, and environmental agencies. Each of the handling methods will be defined and environmental, health, and safety issues will be discussed for each one, along with regulatory oversight. l.lii.a Incineration for Volume Reduction Incineration is a process by which sewage sludge is burned and transformed into gaseous by- products and ash residue. There is a substantial volume and weight reduction, and exhaust ga303 pass through a flue'. "Incineration is a two stop pr000ss consisting of drying and D. la THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA DATE: June 6, 1995 NATTER OF RECORD Supervisor Rogers referred to a study he had read approximately a month ago that was conducted in several cities in the United States in which there appeared to be a correlation between dust dispersal and life expectancy. Noting that dust is an issue with the Keller Landfill, he requested the Health Services Department to track down and review the study in terms of the Keller Canyon Land Use permit. THIS IS A NATTER FOR RECORD PURPOSES ONLY NO BOARD ACTION TAKEN cc: Health Services LEA - Rebecca Ng