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HomeMy WebLinkAbout1988-03-09 (Additional information to Agenda packet EVALUATION AND RECOMMENDATION FOR CONTINUED CODISPOSAL OF WASTEWATER RESIDUALS AND MUNICIPAL SOLID WASTE IN ORANGE COUNTY �SITATIO V ,opolitan 0 e O� `sjnoe 195k 9NGE COUP COUNTY SANITATION DISTRICTS OF ORANGE COUNTY WITH ASSISTANCE FROM K.P. LINDSTROM AND ASSOCIATES February 1987 March 10 , 1987 Mr . Frank Bowerman Director and Chief Engineer Waste Management Program General Services Agency County of Orange 1200 North Main Street, Suite 206 Santa Ana, CA 92701 Subject: Long-Term Continuation and Expansion of the Cooperative Program of the County and the Sanitation Districts for Waste Management Dear Frank: For many years the County Sanitation Districts and the County of Orange have practiced an integrated program of landfill co-disposal of municipal wastewater solids residuals and municipal solid waste. We have been, and remain , most appreciative of the excellent cooperation and assistance that you and your staff have provided. We believe that this close working relationship has enabled us to efficiently and effectively manage waste for the benefit of the citizens and communities that we both serve. The purpose of this letter is to propose the long-term continuation and expansion of the cooperative program of managing metropolitan Orange County' s waste disposal . Specifically, the Districts propose the formal initiation of joint planning and implementation measures for : ' Continuation of the program of co-disposal of wastewater solids residuals and municipal solid waste on a long-term basis at existing County landfills , or at Bee Canyon Landfill consistent with the provisions of the Memorandum of Understanding between the County and the City of Irvine . Provision for future sewage sludge disposal in the "Application for Facility Permit/Waste Discharge" to the Regional Water Quality Control Board for Bee Canyon Landfill . Provision for a leachate control system in the construction of Bee Canyon Landfill in accordance with Subchapter 15 . COUNTY SANITATION DISTRICTS of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O.BOX 8127 FOUNTAIN VALLEY,CALIFORNIA 92728-8127 (714)962-2411 Mr , Frank Bowerman March 10 , 1987 Page Two Implementation of a program of beneficial reuse of sludge as a soil amendment in the closure of Coyote Canyon and Santiago Canyon landfills , and future landfill closures . Implementation of a program providing for disposal of the County' s landfill leachate and landfill gas energy recovery system wastes to the Sanitation Districts ' sewerage system to enhance groundwater protection . In November 1983 , following an extensive evaluation of wastewater solids residuals ( sludge) management alternatives , the Boards . of Directors of the County Sanitation Districts of Orange County (CSDOC) approved a residual solids management plan . The Districts ' evaluation included a review of landfill co-disposal , private sector reuse/disposal , both land based and mechanical composting , co-combustion of sludge and municipal solid waste (MSW) , and ocean disposal . Although the Districts continue to pursue all options , the Boards ' plan designated the continued co-disposal of wastewater solids residuals with MSW at the County' s landfills as the best available short-term alternative and the preferred and most feasible long-term disposal alternative . Landfill co-disposal of sludge and MSW is an environmentally acceptable method, is consistent with the County' s Solid Waste Management Plan and is the most cost-effective means for disposing of sludge from the Districts ' two regional sewage treatment plants serving the residents of metropolitan Orange County. Since the plan was adopted our respective offices have met periodically to informally discuss waste management plans . You and your staff have been most 'helpful . The Districts and their environmental consultant , K. P. Lindstrom and Associates , have completed an "Evaluation and Recommendation for Continued Co-disposal of Wastewater Residuals and Municipal Solid Waste in Orange County" , copies of which are enclosed herewith . The evaluation is an in-depth review of the Districts sludge management program and co-disposal issues . Followi_-7, is a summary of its findings and recommendations in support of the Districts ' proposals : COUNTY SANITATION DISTRICTS of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O.BOX 8127 FOUNTAIN VALLEY.CALIFORNIA 92729-8127 (714)962-2411 Mr. Frank Bowerman _ March 10 , 1987 Page Three Continued Landfill Co-disposal : With the imminent closure of Coyote Canyon in 1988 , the Districts ' review of long-term sludge disposal options has focused on other County landfills and concluded that the most logical site for ongoing co-disposal is the proposed Bee Canyon site . Our evaluation has determined this to be the most feasible alternative for t several reasons : • Bee Canyon is the replacement site for Coyote Canyon (where our existing co-disposal program has been successfully operating for years ) . It is being built to accommodate the wastes from most of Orange County now served by the Districts and it is within the CSDOC service area . The use of Bee Canyon for sludge disposal is consistent with the growing public and political sentiment that each County must be responsible for its own waste disposal . • Bee Canyon , being centrally located yet relatively remote from urban areas , provides the most reliable, long term option for existing and projected waste disposal needs for metropolitan Orange County' s residents . • Bee Canyon is the most cost-effective alternative and reduces transportation requirements and the accompanying environmental impacts . Bee Canyon , being a new site, can be engineered to accept wastewater residuals under the most favorable conditions mandated by Subchapter 15 , using the latest technology. • Bee Canyon revenues ( tipping fees ) from sludge disposal , currently in an amount between $950 , 000 and $1 , 100 , 000 per year paid by the Districts to the County, would remain in the County to the benefit of its taxpayers . The Districts are aware of the Memorandum of Understanding ( MOU) between the County of Oialge and the City of Irvine concerning co-disposal at Bee Canyon Landfill . We fully support the provisions of the MOU, and propose to proceed in a manner consistent with its terms and conditions . Moreover, the 1985 agreement between the Irvine Ranch Water District and CSDOC recognized the mutual benefits to the community of Irvine as well as the Orange County community-at-large in forming new Sanitation District No . 14 . This agreement COUNTY SANITATION DISTRICTS of ORANGE COUNTY, CALIFORNIA. 10844 ELLIS AVENUE " P.O.80X 8127 FOUNTAIN VALLEY.CALIFORNIA 92728-8127 (7141 962-2411 Mr . Frank Bowerman March 10 , 1987 Page Four resolved Irvine' s sewerage planning needs by providing for the conveyance of sewage and industrial waste to the CSOOC regional treatment and disposal facilities in Fountain Valley and Huntington Beach , and recognized the reciprocal benefit of continuing co-disposal of the communities ' wastewater residuals at Coyote and Bee Canyons . The enclosed report discusses at great length the means to comply with the MOU provisions . The initial requirement is the completion of a new Environmental Assessment and Environmental Impact Report (EIR) . However , because of the length of time required to thoroughly perform the CEQA work, it would appear very difficult to complete the necessary environmental reviews within the time constraints of the scheduled opening of Bee Canyon . Therefore , although the environmental work could possibly be completed on a fast-track , it would appear most desirable that the CEQA work relative to co-disposal of sludge at Bee Canyon be accomplished following its opening . The first step in the process is the submittal of an "Application for Facility Permit/Waste Discharge ( Form 200 ) " , to the Regional Water Quality Control Board (RWQCB) which , we understand, the County intends to file sometime in April , 1987 . This is a most important step in the process and , accordingly, the Districts respectfully request that the County, when submitting its application to the RWQCB for Bee Canyon , check Item IV.A. , indicating the potential for future sewage sludge disposal , with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact Report in accordance with the MOU. This would avoid future delays and duplication of regulatory hearings . We propose to work closely with your office and other appropriate parties in processing the application with the RWQCB and in apleting the environmental work. As also discussed in the enclosed report , it would seem appropriate that the Districts be designated the lead agency for CEQA purposes . The Districts would intend to make full utilization of extensive work done to date including the LA/OMA Study. COUNTY SANITATION DISTRICTS t of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O.80X 8127 FOUNTAIN VALLEY,CALIFORNIA 92728-8127 (714)962-2411 Mr. Frank Bowerman March 10 , 1987 Page Five Further , the Districts respectfully request that the County incorporate a leachate control system at Bee Canyon in accordance with the provisions of Subchapter 15 to assure that future operational flexibility including the disposal of sludge at Bee Canyon Landfill is not precluded . We believe that this measure would be desirable, regardless of whether sludge is disposed of at the site . The Districts , of course, will commit to share in the costs of planning and constructing such a system. We will also assist the County in disposing of the landfill leachate by accepting it into our sewer system ( discussed more fully below) . Lastly, with regard to the cost of co-disposal , the Districts have previously committed to work with your office to determine the best means of assuring that the Districts pay their equitable share of such costs . Beneficial Reuse of Sludge in Landfill Closures : The Districts propose to work closely with the County and other affected parties to develop a final closure plan for Coyote Canyon which includes the beneficial reuse of sludge as a soil amendment in the final cover to aid in revegetation and restoration of the site . This would involve extending the Coyote Canyon closure plan from a planned period of six months to as long as two years . Such a program would allow time for Bee Canyon sludge disposal issues to be resolved and to provide an ongoing means of using Orange County ' s sludge . We believe that we can demonstrate that such a program would have significant environmental and economic benefits to the County, the City of Irvine and The Irvine Company ( landfill property owner) as well as to the Districts . Technical assistance can be provided by the Districts to both R the County and The Irvine Company in completing the work necessary to incorporate sludge into the closure plan . Disposal of Landfill Leachate and Co-Generation System Wastes to CSDOC Sewers to Enhance Groundwater Protection : The Regional Water Quality Control Board is requiring landfill leachate collection systems to prevent contamination of groundwater supplies from existing landfills . In addition , the County has been very progressive in proceeding with implementation of co-generation systems to convert landfill methane gas to electricity. The leachate systems and the co-generation installations produce liquid wastes requiring disposal . COUNTY SANITATION DISTRICTS of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O.BOX 8127 FOUNTAIN VALLEY.CALIFORNIA 92728-8127 (714)962-2411 Mr . Frank Bowerman - March 10 , 1987 Page Six The Districts propose to develop a plan , consistent with our industrial waste and groundwater protection policies , to assist the County in disposing of the wastes from your landfill leachate control and co-generation systems to the Districts ' sewers for disposal . We believe that this is a positive environmental program that would enhance the protection of Orange County' s critical groundwater supplies . We are all well aware that growth within our service areas is placing a tremendous demand on our respective agencies . The County is faced with increasing volumes of refuse . The Districts face rising wastewater flows which , coupled with our continual efforts to improve the level of sewage treatment , result in our handling larger quantities of sludge requiring disposal . Clearly, it becomes even more important for us to continue our cooperative program of effectively and efficiently managing the disposal of Orange County' s wastes . At this time landfill co-disposal is the cornerstone of assuring that we meet the disposal needs for the various types of wastes that are generated within the County and should be disposed of within the County , in accordance with the County' s Solid Waste Management Plan and the Districts ' Residuals Solids Management Plan . We look forward to working closely with you and your staff in jointly planning and implementing the extension of our waste management program to augment our ability to serve the residents and communities of Orange County.' After you have had an opportunity to review our proposals I suggest that we meet and continue charting the waste management course that will take us into the next century . n e1 a lvester JG_,q l gera na JWS/pk Enclosures : "Evaluation and Recommendation for Continued Co-Disposal of Wastewater Residuals and Municipal Solid Waste in Orange County" TABLE OF CONTENTS Page No. PURPOSE 1 CURRENT SLUDGE VOLUMES 2 SLUDGE CHARACTERISTICS 3 REGULATORY FRAMEWORK 5 PROJECTED SLUDGE VOLUMES 5 ORANGE COUNTY LANDFILLS 7 Olinda Landfill 8 Santiago Landfill 8 Prima Deshecha Landfill 8 Coyote Canyon Landfi 1 1 11 Bee Canyon 11 BACKGROUND INFORMATION ON CO-DISPOSAL TECHNICAL ISSUES 12 Leachate Collection and Removal 13 Refuse Composition Compared to Sludge Composition 14 Ratio of Refuse to Sludge 16 Summary of Co-Disposal Technical Issues 17 Moisture Balance 19 Leachate Collection and Removal Systems 19 T Haul Distances 21 Regulatory Approvals 21 Environmental Impacts 22 CONCLUSIONS REGARDING CO-DISPOSAL AT COUNTY LANDFILLS 22 ALTERNATIVES TO CO-DISPOSAL 24 USE OF BEE CANYON FOR SLUDGE CO-DISPOSAL 25 TERMS OF THE MOU BETWEEN THE COUNTY AND THE CITY OF IRVINE 26 ENVIRONMENTAL ASSESSMENT AND EIR REGARDING SLUDGE DISPOSAL AT BEE CANYON 27 Lead Agency 27 Responsible Agency 27 EIR Mechanisms 27 RECOMMENDED EIR PROCEDURE 28 Page No. CSDOC PARTICIPATION IN BEE CANYON LEACHATE CONTROL SYSTEM CONSTRUCTION 29 BENEFICIAL USE OF SLUDGE AS SOIL AMENDMENT FOR LANDFILL CLOSURES - 31 COMPLIANCE WITH CONDITIONS OF BEE CANYON MOU 33 Toxicity 34 Technological Advancements 35 LANDFILL LEACHATE AND LANDFILL GAS ENERGY RECOVERY SYSTEM WASTE DISPOSAL TO CSDOC SEWERAGE SYSTEM TO ENHANCE GROUNDWATER PROTECTION 35 IMPLEMENTATION 36 EVALUATION AND RECOMMENDATION FOR ' CONTINUED CO-DISPOSAL OF WASTEWATER RESIDUALS AND MUNICIPAL SOLID WASTE IN ORANGE COUNTY PURPOSE In November 1983, following an extensive evaluation of wastewater solids residuals (sludge) management alternatives , the Boards of Directors of the County Sanitation Districts of Orange County (CSDOC) approved a residual solids management plan. The Districts ' evaluation included a review of landfill co-disposal , private sector reuse/disposal , both land-based and mechanical composting, co-combustion of sludge with municipal solid waste and ocean disposal . Although the Districts continue to pursue all potential options , the Boards ' plan designated the continued co-disposal of wastewater solids residuals with municipal solid waste (MSW) at the County 's landfills as the best short-term disposal alternative and the preferred and most feasible long-term disposal alternative. Landfill co-disposal of sludge and MSW is an environmentally acceptable method, is consistent with the County 's Solid Waste Management Plan and is the most cost-effective means for disposing of sludge from the Districts ' two regional sewage treatment plants serving metropolitan Orange County 's residents . The purpose of this report is to provide information in support of the Districts ' proposals for long-term continuation of the cooperative County and Districts ' program for: o Landfill co-disposal of sludge and MSW at County landfills o Beneficial use of sludge as a soil amendment in the landfill closures as part of the final cover, and o Disposal of landfill leachate and energy recovery plant wastes to the Districts ' sewerage system. -1- CURRENT SLUDGE VOLUMES Any given day CSDOC presently generates up to about 700 wet tons per day of 237.± solids sludge. During the four to five days per week that hauling operations are conducted, CSDOC generates an average of about 35 truck-loads (20 _cubic yards per load) of dewatered sludge for disposal . Up to 26 loads per day (520 tons ) are trucked to the Coyote Canyon sanitary l andfi l l , operated by the County of Orange, located in the foothills near the City of Irvine. This is reported by GSA to be the maximum amount that can consistently be accommodated at this site under the conditions of the County 's operating permit and waste discharge requirements issued by the California Regional Water Quality Control Board (RWQCB) . The remaining truckloads are hauled under contract to the privately owned and operated BKK site located in West Covina in Los Angeles County . During the 1985-86 fiscal year, a total of 5,527 truck-loads were taken to Coyote Canyon (110,540 cubic yards) at an average disposal cost to the Districts of approximately $15.00 per cubic yard (includes transportation and tipping fees) . Assuming an average weight of one ton per cubic yard (actually varies between 1850 and 2150 pounds per cubic yard) it is estimated that about 8,000 to 9,000 tons per month will continue to be hauled to Coyote Canyon for co-disposal with municipal refuse until modified operation and closure begins in the spring of 1988. At that time, the Districts will have to have another operational alternative available to meet sludge disposal needs for both the short-term and long-term. The amount of dewatered sewage sludge solids generated by the Districts ' two regional treatment plants varies with the level of treatment, the effectiveness of the digestion process and the amount of solids captured in dewatering operations . Estimates of the amount of solids generated by the various treatment processes used and the amount generated after digestion and dewatering under various conditions are summarized in Table 1 . -2- TABLE 1 ESTIMATED NUMBER OF TRUCK-LOADS OF SLUDGE GENERATED AT CSDOC TREATMENT PLANTSl (5 day week/basis ) Sludge Generated Est Daily Truck-loads Based on Cake Solids Content . (Wet tpd) 15% 20% 22.5% 400 30 25 23 600 45 38 34 800 60 50 45 1000 75 63 57 1 2 Based on 20 cubic yards per load (one ton/cubic yard) Rounded to next highest number The amount of sludge generated by the present blend of primary and secondary ° treatment needed to meet the CSDOC 301 (h) Modified NPDES permit limitations (75% removal of suspended solids) issued by the California Regional Water Quality Control Board and the U.S. Environmental Protection Agency (EPA) is about 2000 pounds per million gallons treated. The Districts have recently enhanced this treatment by the addition of ferric chloride and polymer (so-called physical/chemical advanced primary treatment) to promote solids removal . This has increased the amount of digested sludge generated by about 20% over what it was a year ago. Under full secondary treatment (if ever required) the Districts - would generate in excess of 840 wet tons per day . SLUDGE CHARACTERISTICS Table 2 presents information on CSDOC sludge quality compared to other plants nationwide. The data presented in Table 2 indicates CSDOC sludge quality is typical of municipal treatment plant sludge. Source control efforts in recent years have resulted in a dramatic reduction in metals loadings to the CSDOC treatment plants . The Districts ' aggressive program of enforcing pretreatment z -3- of industrial wastes at the source has significantly reduced loadings and should result in continued reductions and improved sludge quality in the future (see Attachment 1) . At present, the cadmium content serves as a deterrent to the use of CSDOC sludges for the production of commercial soil amendments . Present DOHS guidelines specify a 50 mg/Kg (parts per million) dry weight limitation for cadmium in soil amendments (California Department of Health Services , 1983) . To achieve this recommended limit, the CSDOC sludge would have to be blended with bulking materials such as wood chips. TABLE 2 EXISTING COMPOSITE DEWATERED, DIGESTED SLUDGE COMPOSITION AND COMPARISON WITH NATIONWIDE QUALITY LEVELS (Combined primary and secondary sludges )* Nationwidel CSDOC 1985-86 Dry Weight Range Actual Cadmium 0.38-1200 69-76 Chromium 6-35,900 434-542 Copper 22- 7,700 1557-1998 Lead 10-28,200 274-293 Nickel 3-13,000 155-258 Zinc 30-34,300 1334-1686 DDT(Total ) 0.006-0.93 ND *mg/kg (ppm) dry weight 1 Source: Camp Dresser & McKee, 1984 -4- REGULATORY FRAMEWORK There are several characteristics of sludge which are important in determining its suitability for reuse in various soil amendment products as well as for disposal via any of a number of alternatives . This report focuses on land-based alternatives in Orange County for recycling and disposal . The important characteristics in determining compliance with existing landfill regulatory standards and quality criteria are evolving as regulations are being modified. The basic California regulatory criteria consists of the Title 22 (Department of Health Services (DOHS) ) and Title 23, Subchapter 15 (State Water Resources Control Board (SWRCB) ) regulations regarding the classification of wastes as non-hazardous , designated (wastes which impair water quality ) or hazardous. Testing data has shown CSDOC sludges to be non-hazardous according to all existing State criteria. New U.S. Environmental Protection Agency technical regulations are being promulgated which will establish both numerical criteria and management practices with regard to sludge disposal . States will have to prepare state-wide sludge management programs incorporating these regulations as minimum standards . At present, the classification of landfills and wastes such as sewage sludges is being evaluated under the provisions of Subchapter 15 regulations under the authority of the SWRCB and the various Regional Water Quality Control Boards. Until the EPA technical regulations are drafted in 1987, sludge regulatory criteria will continue to be in a state of flux and subject to site-by-site and project-by-project evaluation and negotiation with regulatory agencies . PROJECTED SLUDGE VOLUMES The amount of sludge generated by the Districts ' operations in recent years has increased dramatically as a result of improved treatment. A summary of the change in average generation rates (quantities of residuals generated for -5- disposal ) of wastewater derived solids (includes screenings , grit and sludges ) -� at the Districts ' two regional treatment plants over the past ten years is presented in Table 3. TABLE 3 ANNUAL AVERAGE CSDOC FLOW AND SLUDGE GENERATION CHANGES 1976 and 1986 CSDOC Service CSDOC Joint Total Solids Total Sludge (wet) Area Works Influent Generatedl tons/day Year Population Flow, mgd lb/capita/day Generated 1976 1,520,000 184 0.18 137 1986 2,200,000 240 0.36 396 Change 680,000 56 0.18 259 Percent Change 45% 30% 100% 189% 2 Includes screenings and grit Annual average based on 365 days As indicated, over the past decade, the amount of wastewater flow treated has increased by about 30%, while the amounts of solids generated on a per capita basis has increased by 100%. Sludge removed from the plants has increased by an estimated 189%. This dramatic increase is not expected to continue at such a disproportionate rate since treatment is estimated to remain at the same relative level over the next few years if the California Ocean Plan removal level (75 percent removal of suspended solids ) is retained. However, the rate of solids removal is still expected to increase at a greater rate than the expected rate of flow increases due to continued efforts to improve treatment and to comply with the mass emission limit in the District ' s NPDES permit. The implementation of chemically enhanced advanced primary treatment has increased sludge production recently by about 120 cubic yards per day. This 120 cubic yard increment will be variable, depending upon the level of advanced -6- primary treatment utilized by the Districts. Should secondary treatment be required in the future as a result of changes in the California Ocean Plan or the District 's 301 (h) Modified NPDES permit after 1990, sludge production could increase by at least another 20%, based on todays flows. - Such improvements in treatment have in the past and will in the future increase the amounts of sludge that must be trucked to landfill disposal locations and underline the need to find additional means of beneficial reuse and/or disposal as Coyote Canyon landfill phases out of service. ORANGE COUNTY LANDFILLS Landfilling appears to be the most reliable, cost-effective long-term option for the Sanitation Districts and will always be needed as a back-up even if other sludge disposal options are implemented. Following is a brief discussion of current and proposed Orange County landfills and their potential use with regard to co-disposal of sludge and MSW. The County of Orange General Services Agency, Waste Management Program, presently operates four sanitary landfills (Ol i nda, Coyote Canyon , Santiago Canyon and Prima Deshecha) . Both Coyote and Santiago are scheduled to close (having reached capacity) within the next two to five years. A proposed new landfill , Bee Canyon , has been approved as a replacement site for Coyote and construction of improvements (roadways, etc. ) to make it operational by the spring of 1988 are underway. A replacement site for Santiago is under investigation. A summary of the present operations of the four currently operating sites is shown in Table 4. Their locations in relation to the Districts ' facilities are shown on Figure 1. -7- Olinda Landfill . This landfill is located in a deep canyon on the northerly end of the extension of Valencia Avenue north of the City of Brea. The site and adjoining canyon, designated Olinda Alpha, encompass 570 acres . The site was opened in 1960 and at present receives an average of 3219 tons per day of refuse. No sewage sludges are presently being taken to the Olinda site. It is expected to reach its capacity to accept wastes by 1994. Santiago Landfill . The site encompasses a 160 acre canyon off Santiago Canyon Road west of Irvine Lake. This site is leased from The Irvine Company and is expected to reach its capacity by 1990. It is not receiving any sewage sludge at present and takes in an average of about 1317 tons per day of refuse. Prima Deshecha Landfill . This large 1500 acre site is located three miles east of the intersection of Interstate 5 (San Diego Freeway) and the Ortega Highway. This site, opened in 1976, is owned by the County and presently receives about 901 tons per day of refuse and about 70 wet tons per day of sludge. It differs from the other sites in that it is under the jurisdiction of the San Diego RWQCB (Region 9) rather than the Santa Ana RWQCB (Region 8) . Its waste discharge requirements specify a 15% minimum solids content for sewage sludges versus the 22.5% requirement which exists at Coyote Canyon . It presently receives sludges from the following agencies: Aliso Water Management Agency (AWMA) South East Regional Reclamation Authority (SERRA) City of San Clemente The Prima Deshecha site is expected to continue operations through the year 2000 and well beyond. -8- TABLE 4 SU4WY OF COUNTY OF ORANGE LANDFILL OPERATIONS (6 day week, 260 days per year) Waste Received Disposal Volume Total (Tons) (Cubic (Million CU. Yd.)(c) Estimated Area per day Yards) Remaining Jurisdiction (Acres) (a) (Per Year)(b) In Place Remaining Life (Years) Wastes Received Operating Regulations Olinda-Alpha 515* 3219 8,531,000 36.5 11.1 8 (1994) Nonhazardous State Minimum Standards (d) Coyote Canyon 670 4197 8,752,000 51.0 12.3 2 (1988) Nonhazardous and State Minimum Standards (d) Sewage Sludge Santiago 160 1317 4,324,000 12.1 0.9 4 (1990) Nonhazardous State Minimum Standards (d) Prima Deshecha 1500 901 2,783,000 6.4 73.2 >18 (2004) Nonhazardous and State Minimum Standards (e) Sewage Sludge * Additional 55 acre acquisition being negotiated (a) Based on fee collection data, fiscal year 1984-85 (b) In place fill based on 1,200 pounds per cubic yard (c) Estimated in-place remaining as of January, 1986 (d) Title 14 requirements and Waste Discharge Requirements from Santa Ana RWQCB (e) Title 14 requirements and Waste Discharge Requirements from San Diego RWQCB FIGURE 1 --� ban :-arnarcinc BREA County BREA O L]N D A 57 YORBA UNDA River PLACENTIA Ana 91 91 ANAHEIMH?LLS Riverside County AMAHElh9 y111A SANTlAGO PARK CANYON ORANGE -, � Irvine Lake �Q SILVERADO TUSTiM CANYON SANTA ANA 55 5 MODJESKA MINE BEE TR OAA6XS UC0 CANYON Q 4.05 q COTO DE 133 TORO CAZA CORONA DEL hW COYOTE LAGUNA yNEWPOR,T CANYON HILLS MISSION gq VIEJO CAGi11tA•. PRIMA MACH LAGUNA D E S H E C H NIGUEL fpp SAN JUAN ` CAPISTRANO BEACH Lp . SANS. j GUS KELI M / Loa Angeles Times Locations of existing Orange County landfills. -10- Coyote Canyon Landfi 11 . This site is the most important site at present for the disposal of sewage sludge from Metropolitan Orange County . The Districts , which serve 85% of the County 's citizens , take a majority of their sludge to this site far co-disposal with refuse. The landfill is located one mile south of Bonita Canyon Road between the cities of Newport Beach and Irvine. The site is leased from the Irvine Company. The original 563 acre site was opened in 1963 and expanded in 1977 to 670 acres . In February of 1984, the County Board of Supervisors approved an EIR for the expansion of the landfill to extend its useful life until 1988 when a replacement site (Bee Canyon) would be constructed and ready to start accepting waste now going to Coyote. Recently, there has been considerable discussion relative to leachate from the landfill entering local drainage areas tributary to Newport Bay. The County commissioned a technical evaluation of the site 's water management, has proposed a program to control leachate and is in the process of implementing such a program. Bee Canyon In 1970-71, the County Road Department investigated more than 50 possible sites to accommodate the County 's future solid waste disposal needs . In 1974-75, a state-mandated County Solid Waste Management Plan was prepared. A major requirement of this plan was to find a replacement for the Coyote Canyon landfill . After evaluating the alternatives , it was determined that a site in r the Lomas de Santiago foothill area was the most suitable general area for a new landfill . In 1976, a Task Force consisting of County staff and consultants studied 25 potential sites , using six environmental screening criteria. As a result of these evaluations , five sites in Bee and Round Canyons were selected for further consideration due to their favorable rankings in terms of remoteness from urban areas, remoteness from the Sinks (a unique geologic area proposed as a park ) , the ability to construct effective access roads, and their lack of -11- visibility from existing and proposed residential developments (Lockman & Associates/PRC Toups , 1979) . Eleven alternative site designs for the two canyons were evaluated which encompassed one or both of the canyons and ranged in size from 65-1060 acres . The basic differences among the plans- were their maximum and average fill heights and the acreage consumed which together provided the rated capacity. Eventually Bee Canyon was selected and an EIR was prepared to support development of a 362 acre site. BACKGROUND INFORMATION ON CO-DISPOSAL TECHNICAL ISSUES The co-disposal of sludge with municipal solid waste is now the subject of specific regulations adopted by the SWRCB under Subchapter 15 as well as federal criteria under the provisions of the Resource Conservation and Recovery Act (RCRA) . Basically, the regulations state that sludges must be nonhazardous and shall not contain soluble constituents in concentrations which exceed applicable water quality objectives or could cause degradation of the waters of the state (i .e., are designated or hazardous wastes ) . Waste classification is done through the use of special testing methods developed by the California Department of Health Services to determine the total and soluble concentrations of 37 different compounds, or EPA's extraction test which measures 52 different compounds using a different extraction procedure. Exceeding any of the levels set for these substances can result in the classification of a waste as hazardous . Also, efforts are underway to determine the appropriate water quality objectives to apply to the classification of designated wastes which must go to either a Class I or II landfill . Wastes which are not hazardous or designated and meet the other criteria for non-hazardous wastes can be discharged at a Class III landfill . It is believed that the Districts ' sludges meet all of the criteria for Class III landfill disposal . The regulations specifically address co-disposal of refuse and sludge and state the following (Section 2523c of Subchapter 15) : -12- "Dewatered sewage or water treatment sludge may be discharged at a Class III landfill under the following conditions, unless DOHS determines that the waste must be managed as a hazardous waste: 1) The landfill is equipped with a leachate collection and removal system; 2) The sludge contains at least 20 percent solids if primary sludge, or at least 15 percent solids if secondary sludge, mixtures of primary and secondary sludges , or water treatment sludge; and 3) A minimum solids-to-liquid ratio of 5: 1 by weight shall be maintained t to ensure that the co-disposal will not exceed the initial moisture-holding capacity of the nonhazardous solid waste. The actual ratio required by the Regional Board shall be based on site specific conditions." These regulations raise several issues which must be addressed in order to determine to what degree co-disposal can be practiced and which landfills can practice it. These issues are the presence of a leachate collection and removal system, the sludge characteristics, classification and percentage of solids, and the minimum solids-to-liquid ratio that is acceptable to the RWQCB based on site specific conditions (if it differs from the minimum 5: 1 requirement. ) The specific sludge to refuse mix is related directly to the leachate generation issue, which is the heart of the co-disposal issue. To provide some perspective on this issue, the subject of leachate and the composition of sludge versus that of refuse are discussed below. Leachate Collection and Removal Leachate is the fluid waste that can be generated by landfills when excessive moisture is present that exceeds the holding capacity of the fill material . Landfill leachate potentially can pose a threat to both surface and groundwater -13- quality due to its characteristics (U.S. EPA, 1985) . Fortunately, the nature of the wastes placed in landfills in Southern California, combined with the dry climate and landfill practices (no liquid wastes accepted) , generally preclude the formation of leachate in most instances . Landfill practices which provide daily cover to minimize infiltration of rainfall combined with diversion of surface runoff around a site prevent excessive amounts of water from entering rlandfills. If landfill leachate does form, many of the constituents present are removed as it passes through the unsaturated soil zone. However, if rlandfill leachate is increased in volume by springs or seeps which can form in fractured geologic structures , it may impact groundwater or surface streams. To preclude such potential problems, the SWRCB in adopting the Subchapter 15 rrequirements for sludge disposal in 1984, took a conservative approach and M• assumed that landfill leachate will form if co-disposal is practiced. Thus , a leachate collection and removal system is required for new landfills practicing 5 co-disposal and an analysis of the moisture-holding capacity of the waste is required if anything less than a 5: 1 ratio is proposed. r Refuse Composition Compared to Sludge Composition The general composition of solid waste in Orange County and the various sources r of waste that are being landfilled are presented in Table 5. Comparative amounts of water present in sludge and refuse are quite different as indicated by the data presented. Municipal Solid Waste or refuse has a moisture content average about 20%, while sludge has a moisture content on the order of 75% (25% solids by weight) . Also, sludge composition differs from refuse primarily in the concentration of trace metals and organics contained within it. In terms of elemental compositions and the amounts of trace metals and other potential P pollutants , there is very little information on the composition of any "typical " MSW. The composition varies dramatically on a daily, weekly, monthly and annual rbasis. Unlike refuse, which can contain almost anything including hazardous r -14- TABLE 5 SELECTED PER CAPITA SOLID WASTE GENERATION RATES Moisture Generation Range Orange County Percent Moisturel . Source Category lb/Capita/Day lb/Capita/Day Range Typical Combined household 2.0-5.0 6.0 15-40 20 and Commercial Industrial 1 .0-3.5 0.1 --- --- Institutional 0.24 --- --- --- Construction Debris 0.66 1 .9 --- --- Street Sweepings 0.25 0.10 6-12 --- Tree and Landscape 0.18 0.10 30-80 60 Park and Beach 0.16 --- --- --- Catch Basin 0.04 --- 6-12 --- Sewage Treatment 0.20-0.50 0.202 85-60 75 Plant Solids (Dewatered) Overall 7.9- 20.2 8.5 1Source: Tchobanoglous , et . al , 1977. 2Estimate in County Solid Waste Management Plan Actual CSDOC rate now 0.36 lb/capita/day (See Table 3) 3National Range ,I -15- wastes , wastewater derived sludge has been pretreated if originating from a major industrial source, and has a relatively stable composition since the sludge is stored and stabilized for a thirty day period in large covered vessels called digesters , thus providing a relatively uniform composition: Variation in the metal content of CSDOC sludge was shown in Table 2. Analysis of refuse will show highly variable results as would be expected. Ratio of Refuse to Sludge At the present, Coyote Canyon co-disposal must achieve a minimum volumetric mixing ratio of refuse to sludge of at least 10: 1 according to the waste discharge requirements formulated by the RWQCB. During the last full year of operation, Coyote Canyon received a total of 2.27 million cubic yards of waste material (which included sludge) . During this period, CSDOC hauled 110,540 cubic yards of sludge to Coyote Canyon landfill . Thus , about 2,174,278 cubic yards of waste other than sludge was received which indicates that sludge accounted for only 4.8% of the waste received on a volumetric basis. On a weight basis , sludge accounted for just 7.5% of the estimated tonnage received (95,840 tons of sludge versus 1 .3 million tons of refuse at 1200 pounds per T cubic yard) . The amount of wastes received at all existing County landfills over the past three years is shown in Table 6. As indicated, loading at Santiago and Prima Deshecha has increased, while loading to Coyote Canyon and Olinda has fluctuated slightly, both upward and downward. Based on the average loadings over the past three years, the capacity to accept sewage sludge at the existing County landfills was estimated based on two mixing ratios (a minimum of 5:1 as specified for landfills equipped with an LCR system and 10: 1 under different existing permit limits for co-disposal . ) This information is presented in Table 7. -16- Typically, refuse at a moisture content of about 20 percent represents about 28 gallons of water per cubic yard of refuse (48 gallons per ton) . Sludges vary in moisture content between 70 and 85 percent and contain between 155 and 188 gallons of water per cubic yard or about 167-203 gallons per t-on. On the _4 average, the moisture content of a ton of sludge is equivalent to that of about four tons of refuse, which is why the 5: 1 minimum mixing ratio is specified in the Subchapter 15 regulations . Based on the moisture content of refuse and sludge and a minimum solid to liquid ratio of 5:1 by weight, the capacity of Orange County landfills to assimilate sewage sludge via co-disposal was - estimated. Using these estimates , the number of truck-loads of sludge which can be potentially disposed of at present landfills was calculated under a variety of mixing ratios and varying percentages of sludge solids . These estimates are presented in Table 7. This present mixing ratio and waste volume currently restricts the Districts from taking more than 26 trucks per day to -_ Coyote Canyon . Assuming a 22.5% solids sludge and 10: 1 mixing ratio, the County of Orange landfills could potentially accommodate a total of an additional 31 truckloads per day of sludge (Table 8) . Olinda has the greatest potential capacity and could handle up to 18 truck-loads of sludge. Santiago could handle about eight truckloads a day. Prima Deshecha 9 9 9 Y could presently assimilate about five truckloads a day of sludge which would only allow an additional two truckloads per day over and above that now being accepted from other agencies . As the waste loads change due to growth in the waste generation of the various service areas, these estimates will change. Summary of Co-disposal Technical Issues Of primary importance to the continuing cooperative program of the County of Orange and the Sanitation Districts for co-disposal are moisture balance and f -17- TABLE 6 AMOUNT OF WASTES RECEIVED ANNUALLY - AT ORANGE COUNTY LANDFILLS 1982-1985 (cubic yards received) Landfill 1982-83 1983-84 _ 1984-85 Coyote Canyon 1,977,000 2,368,250 2,269,418 Olinda-Alpha 1,772,449 1,780,137 1,420,697 Santiago 863,274 971,050 1,183,240 Prima Deshecha 540,876 618,000 665,000 Total (cubic yards ) 5,103,599 5,737,437 5,538,355 Total (tons ) 3,062, 159 3,442,462 3,323,013 Overall Daily Avg (yd3)1 13,982 15,719 15,173 for County (tons ) 8,389 9,431 9,104 1Based on 365 days/year generation and operation TABLE 7 ESTIMATED CAPACITY OF ORANGE COUNTY LANDFILLS TO ASSIMILATE SEWAGE SLUDGE Landfilll Sludge Disposal Capacity Based on Daily Refuse:Sludge Ratio Truck Loads at Different Percentage Solids2 15% 20% 22.5%* 25% 30% Coyote Canyon 5:1 42 45 48 50 53 10:1 21 23 24 25 26 Olinda-Alpha 5:1 32 34 36 38 40 10: 1 16 17 18 19 20 Santiago -- 5:1 13 14 15 16 17 10:1 7 7 8 8 9 - Prima-Deschecha 5:1 9 9 10 10 11 10: 1 4 4 5 5 6 l Assumed average daily waste received (tpd) at 20% moisture: Coyote (4200) ; Olinda (3200) ; Santiago (1300) ; Prima Deschecha (900) 2 Assumes 20 cubic yards per load for 100 dry tons (annual daily average) *Current RWQCB requirement for CSDOC sludges disposed at Coyote Canyon -18- leachate generation considerations , haul distances , regulatory approvals , environmental impacts. Each of these topics is discussed below. Moisture Balance. A comparison of annual moisture inputs into landfills in the County provides an important perspective on how sludge, as a source of moisture, affects potential formation of leachate. Based on an average moisture content of 20%, refuse disposal contributes an estimated 3.28 million pounds/day of water or about 393,000 gallons/day to landfills. The 400 wet tons/day of sludge now received at about 77% moisture, contributes about 92,300 gallons/day. Overall , some 8200 tpd of refuse is generated compared to 400 tpd of sludge. Sludge represents only about 5% of the waste load and about 19% of the moisture content which totals some 485,000 gallons/day. Leachate Collection and Removal Systems. California requires landfill leachate collection and removal systems (LCR Systems) in all new Class I or Class II landfills , surface impoundments and waste piles (CAC , Section 2543) ; and for Class III landfills which have a liner or accept sewage or water treatment sludge. Such systems must be installed directly above the underlying containment features (either natural or man-made) for landfills. These systems normally consist of a permeable subdrain layer which covers the bottom of the waste management unit. If a Class III landfill is required to have an artificial liner, then a dendritic landfill leachate collection and removal system which underlies less than 100 percent of the. waste may be allowed. Leachate collected by the system shall either be recycled to the landfill or discharged in another manner approved by the RWQCB. Once installed, these systems must be designed and operated so as to function without clogging through the entire life of the landfill and during the post closure maintenance period . The systems must be tested at least annually to demonstrate that they are working properly. At present none of the County landfills are equipped with LCR Systems, and most cannot be economically retrofitted, thus co-disposal of sludge will be dependent -19- TABLE 8 SLNvIARY DESCRIPTION OF POTENTIAL ORANGE COUNTY LANDFILL Truckloads Fill Capacity Estimated Round Trip Haul of Sludge (106 yd3) Remaining Distance From CSDOC (Miles) Which Could Be Landfill Acreage Ultimate Remaining Life (Yrs) Plant #1 Plant #2 Assimilated Coyote Canyon 653 44 4+ 2 18.4 31.8 24 Olinda-Alpha 565 46.6 11.1 8 53.4 64.2 18 Santiago 160 13.4 0.9 4 39.6 50.4 8 N Prima Deshecha 1464 130 73 >18 62.0 72.8 5 0 Bee Canyon* 362* 109 109 >20 45.9 56.7 30 est *Planned 1Based on 22.5% solids and 10:1 mixing ratio (see Table 7 for various scenarios). upon site-by-site evaluation of the potential for leachate generation. Such evaluations may be required by the RWQCB having jurisdiction over the landfill in order to modify existing waste discharge requirements . Haul Distances . The haul distance from the CSDOC facilities to the various County landfills is an important factor due to the number of trips that can be made per day, costs , and air pollutant emissions , fuel use, etc. As shown in Table 8, Coyote Canyon has the shortest haul distance of the existing landfills. The next closest existing site is Santiago followed by Olinda. Prima Deshecha is much farther than other sites . The Bee Canyon site has the most favorable haul distance once Coyote Canyon closes , as well as sufficient capacity and useful life to serve future District needs . However, as discussed later, the use of this site for sludge disposal has to undergo ' an environmental assessment process and approval before it can be utilized. Other existing sites could also be utilized, particularly if a certain amount of sludge is trucked to each of the existing sites , thus minimizing the sludge impact to any one site. Permit modifications and environmental review requirements would have to be completed for the existing sites as well . Regulatory Approvals. Regulatory approval (waste discharge requirements from RWQCB) for co-disposal of CSDOC sludge at County landfills is expected to take as long as six to nine months once technical evaluations are completed unless some urgency is demonstrated. A joint effort by the County and the Districts would be required. The County Solid Waste Management Plan does not appear to preclude sludge disposal at any of the County 's existing or proposed landfills provided the provisions of Subchapter 15 are met and NPDES permit conditions can be met. -21- Environmental Impacts . The environmental impacts associated with co-disposal are similar to those associated with refuse disposal and include the following: o Direct air pollutant emissions from trucking and landfilling equipment. o Indirect air pollutant emissions from landfill gases . o Energy use in the form of fuels for transportation and equipment. o Potential for leachate formation. o Potential exposure to pathogens for landfill personnel if proper procedures are not followed. o Landfill gas production and enhanced waste decomposition, promoting more uniform settling and the potential for energy recovery if gas is captured and used. o Minimized odor generation compared to composting since waste is now buried and covered on a daily basis . o Use of landfill capacity at a greater (although nominal ) rate than would otherwise occur. o Other processing or disposal sites are not needed, thus containing impacts to an area already dedicated to waste disposal . Sites can be used for other beneficial uses once the landfill is completed and the surface is restored. CONCLUSIONS REGARDING CO-DISPOSAL AT COUNTY LANDFILLS K. P . Lindstrom & Associates , environmental consultant to the Sanitation Districts , has concluded from the preliminary evaluation of landfill disposal of CSDOC sewage sludges at Orange County landfills: Co-disposal is a recognized, environmentally acceptable practice and is consistent with the County 's Solid Waste Management Plan. -22- o There is potential capacity to accommodate the Districts ' current sludge production and the projected sludge production in the foreseeable future under current regulatory constraints. o By increasing the dewatering efficiency or reducing the mixing ratio, even more sludge could be accommodated. o The issues which must be addressed in gaining approval include increased truck traffic (minor) , permit modifications , and changes in existing operating procedures to incorporate sludge at the optimum mixing ratio with refuse. Preliminary evaluation shows few technical constraints that would impede use of the landfills for co-disposal provided County cooperation. o Based on the District 's ongoing evaluation of all available sludge disposal and reuse options , co-disposal at Bee Canyon continues to appear to be the most feasible alternative for several reasons: • As the replacement site for Coyote Canyon, where our existing co-disposal program has been successfully operating for years, it is being built to accommodate the wastes from most of metropolitan Orange County now served by the Districts and it is within the CSDOC service area. This is consistent with the growing sentiment that each county be be responsible for its own waste disposal . • Being centrally located yet relatively remote from urban areas it provides the most reliable, long-term option for existing and projected waste disposal needs for metropolitan Orange County 's residents. • It is the most economical alternative and reduces transportation requirements and the accompanying environmental impacts (air quality, energy use, etc. ) . -23- • Being a new site it can be engineered to accept wastewater residuals under the most favorable conditions mandated by Subchapter 15 using the latest technology . • Revenues from sludge disposal (tipping fees ) in an amount between $950,000 and $1,100,000 per year paid by the Districts to the County of Orange remain in the County and benefit its taxpayers. The County and the Districts have a longstanding history of working closely together on landfill co-disposal of Orange County ' s wastes . It is the n Districts ' desire, as in the past, to continue the excellent relationship and provide ongoing support of the County 's landfill operation . In addition, the Districts wish to continue working with the County to determine the best means of assuring that the Districts pay their equitable share of co-disposal costs. ALTERNATIVES TO CO-DISPOSAL. The EIR for the Bee Canyon landfill , finalized in the fall of 1979, did not address the sludge disposal issue because at that time sludge disposal was being addressed by an independent multi -million dollar regional sludge study and environmental planning and review which was an outcome of the LA/OMA Study in which the Districts participated. At the time, it was envisioned that the Districts would construct a sludge drying/composting facility adjacent to Bee Canyon, at a site in Lower Round Canyon, for processing sludges to meet the then existing RWQCB 50% solids requirement prior to landfilling at Bee Canyon . Alternatively, if a suitable market could be found and the quality criteria for reuse could be met , the Districts would sell the dried sludge for use in the production of soil amendments . Following public comment on this proposed project in 1981, the Districts ' Boards of Directors took an action to re-evaluate other alternatives , including -24- mechanical composting in enclosed structures and co-combustion with municipal refuse using the existing treatment plant sites . Based on public input on these alternatives in 1983, the Districts ' Boards of Directors discontinued further consideration and determined that the best alternative was the continuation of co-disposal at County landfills. The Districts have, concurrently, pursued other alternatives . In September, 1984, a 20 year contract for long-term sludge reuse/disposal was executed with a private firm. However, the firm has faced insurmountable obstacles and, thus , has been unable to perform its contractual obligations. It appears as if there is very little likelihood that they will be able to perform in the foreseeable future. The Districts have also sought federal legislation that would permit a research project off Orange County 's coastline to demonstrate the benefits of deep ocean disposal of sludge which is not presently permitted by law. However, that project, if approved, would not result in any final federal decision on the allowability of ocean sludge disposal for 12 to 15 years. The Districts have made a concerted effort to implement alternative dipposal/ reuse options and are committed to continue seeking alternatives . USE OF BEE CANYON FOR SLUDGE CO-DISPOSAL A continuation of the cooperative program between the County of Orange and the Sanitation Districts is essential for assuring ongoing co-disposal of Orange County 's wastes . This is particularly important with regard to the most logical alternative, the Bee Canyon landfill . The Districts and the County should work closely together during the process of completing technical studies and securing needed approvals to provide the future availability of landfill disposal capacity to serve the needs of our citizens. -25- A coordinated effort will be needed to obtain the information needed to file an application for a Facility Permit/Waste Discharge (Form 200) , and in the permit application and review process to secure requirements for the Bee Canyon landfill to assure that sludge co-disposal at Bee Canyon, consistent with the terms of the Memorandum of Understanding (MOU) between the County and the City of Irvine and Subchapter 15, is not precluded. The submittal of the Application for Facility Permit/Waste Discharge to the z Regional Water Quality Control Board is one of the most important steps in the process. The Districts recommend that the County, when submitting its application to the RWQCB for Bee Canyon, check Item IV.A., indicating potential future sewage sludge disposal , with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact T Report in accordance with the MOU. This would avoid delays and duplication of regulatory hearings . The Districts would propose to work closely with the County and other appropriate parties in processing the application with the RWQCB and in completing the environmental work. Terms of the Memorandum of Understanding Between the County and the City of Irvine. The Districts fully support the provisions of the MOU between the County of Orange and City of Irvine. It requires completion of a new Environmental Assessment and Environmental Impact Report (EIR) and specifically requires that certain other actions be taken relative to co-disposal at Bee Canyon . Among these are 1) 10: 1 mixing ratio of refuse to sludge, 2) toxicity testing of sludge with the results to be reported to the City of Irvine and, 3) exploration and implementation of new technologies as they develop that will mitigate potential problems related to sludge disposal at Bee Canyon. -26- Environmental Assessment and Environmental Impact Report Regarding Sludge Disposal at Bee Canyon To initiate any new disposal program will require compliance with the provisions of the California Environmental Quality Act (CEQA) . The following discusses various options for fulfilling this need for landfill disposal at Bee Canyon . Lead Agency: On a County of Orange project, such as the Bee Canyon landfill , the County normally serves as the Lead Agency under the provisions of CEQA. The County Planning Department normally is responsible for the preparation of an EIR or coordinating its preparation through or by a consultant hired by the County or the project proponent. According to CEQA (Section 21066) , a Lead Agency is the public agency which has the principal responsibility for carrying out or approving a project which may have an effect on the environment. This implies that the Lead Agency for the MOU Sludge EIR is the County, who will operate Bee Canyon and must secure the permits. However, the County could delegate responsibility for the preparation of the EIR to CSDOC as a logical extension of the previous EIR/EIS work done by the Sanitation Districts (LA/OMA) to determine the best alternative for long-term sludge disposal . Responsible Agency: When an Environmental Assessment/EIR is undertaken, the City of Irvine will serve as a Responsible Agency. The County of Orange has T already fulfilled the requirements of CEQA for Bee Canyon, and secured project approval (Resolution 79-1409 adopted September 25, 1979 and certification of EIR 018 [Revised]) . It will be important to assure that any new EIR be specific to the sludge disposal issue and not result in a change in the status of the previously approved EIR. EIR Mechanisms: There are several mechanisms to satisfy CEQA EIR requirements. One alternative is a Subsequent Draft EIR (CEQA Section 15162) to address "new information of substantial importance to the project" and this information shows -27- that "mitigation measures or alternatives which were not previously considered in the EIR would substantially lessen one or more significant effects on the environment." The "new information" applies to the air drying needed and the adoption of new standards pursuant to Subchapter 15. _ If only minor revisions to the 1979 EIR are required (just the sludge disposal issues ) , another alternative would be to prepare- a Supplement to the EIR (Section 15163) . An Addendum to the EIR (Section 15164) could also be prepared assuming that only minor technical changes or additions are necessary to make the EIR under consideration adequate under CEQA" and new issues are not raised. We have included excerpts from CEQA that discuss these various EIR options (Attachment 2) . Recommended EIR Procedure After evaluating all the available options it is recommended that the Districts serve as the Lead Agency for preparation of a new EIR specifically addressing a permit modification for the Waste Discharge Requirements and fulfillment of the terms of the MOU. As indicated in Figure 2, work on the EIR would have to begin immediately in order to complete it and secure a permit modification prior to commencement of the Coyote Canyon closure in April of 1988. Although October 1988 is the projected actual closure date, Coyote will only be taking 700 tpd FF after April 1988 when wastes will start to be diverted to Bee, thus the Districts rwill only be able to dispose of about 25-30% of their sludge at Coyote during r the six month transition period. Extraordinary diligence would be required of all involved parties for the EIR to proceed according to schedule. Sufficient time may not be provided in this schedule since our past experience has shown delays in both the EIR process and in securing RWQCB approval which can be P expected. r -28- It would appear desirable that Bee Canyon be in operation before the EIR on sludge disposal is initiated. However, to delay the EIR preparation would mean a loss of a major District co-disposal option beginning in April of 1988 for a minimum one and a half year period . This presents a major problem for disposing of the sludge produced by the communities in metropolitan Orange County unless other landfill sites can be used or the Districts can find extended reuse options . An attractive solution would be a major reuse project for the beneficial utilization of sludge as a soil amendment for the closure of Coyote and Santiago Canyon Landfills, which is discussed more fully in a subsequent section. T CSDOC PARTICIPATION IN BEE CANYON LEACHATE CONTROL SYSTEM CONSTRUCTION A major change in the nature of the waste discharge requirements has occurred since the LA/OMA project was initiated. These changes preclude the need for air drying to achieve a 50% solids content and make direct landfill co-disposal with refuse feasible provided that the Class III landfill is equipped with leachate collection and removal (LCR) capability and has a solids content of at least 15% and is mixed with refuse at a minimum ratio of 5: 1 at a Class III landfill with ,r an LCR system (Subchapter 15, Section 2523) . We understand that classification of the Bee Canyon site will depend on the results of on-site geological and hydrogeological investigations now underway. Results of this work will indicate whether or not a clay liner may be necessary to protect groundwater resources . The Districts recommend that the County give serious consideration to incorporating a leachate control system at Bee Canyon in accordance with the provisions of Subchapter 15 to assure that full flexibility of operation including future disposal of sludge at Bee Canyon Landfill is not precluded. It is believed that this measure would be desirable regardless of whether sludge is disposed of at the site. -29- FIGURE 2 PLANNING ACTIVITIES AND SCHEDULE FOR COMPLETION OF EIR RELATED TO LANDFILL DISPOSAL OF SLUDGE AT BEE CANYON OPTION 1 Fast-Track EIR ACTIVITY TIME Analyze District sludges for Regulatory Compliance Ongoing Meeting with Top GSA staff March, 1987 Meeting with Regional Board regarding sludge April , 1987 classification as a waste Prepare detailed written status report and issue April , 1987 identification paper summarizing status of sludge projects for submittal to appropriate agencies Meeting with major affected entities to scope out April , 1987 R EIR and develop schedule of activities Issue Notice of Preparation of Draft EIR April , 1987 Hire EIR Consultant (Request CSDOC Board Action) May, 1987 Complete Screen-Check Review Draft of EIR October, 1987 Circulate Draft EIR December, 1987 Public Hearing January, 1988 Certify Final EIR February, 1988 Initiate Permit Change for Waste Discharge February, 1988 Requirements with RWQCB (Formally) Secure Permit Modification By April , 1988 NOTE: This schedule provides a final window of less than two months in which to secure the desired permit change to allow for sludge disposal in Bee Canyon from the Regional Water Quality Control Board. Thus , the EIR preparation must begin as soon as possible and be completed on a fast-track . -30- The Districts propose to share in the costs of planning and constructing such a system. The Districts further propose to assist the County in disposing of the landfill leachate by accepting it into the CSDOC sewerage system which is discussed more fully in a later section. - BENEFICIAL USE OF SLUDGE AS SOIL AMENDMENT FOR LANDFILL CLOSURES The Districts hereby formally propose that sludge be utilized as a soil amendment and cover material in the closure of Coyote Canyon and Santiago Canyon landfills. This would involve extending the Coyote Canyon Closure Plan from a planned period of six months to as much as two years, but the Districts firmly z believe that there are substantial benefits to the County, the City of Irvine, the Irvine Company (landfill property owner) and the Districts. We propose to continue to work closely with the County and other affected parties on implementing such a program. The beneficial use of sludge will enhance revegetation and beautification of the site, preclude the need for importing cover, have economic benefits and would provide an interim disposal solution . The County is working on a plan for final closure of Coyote Canyon in 1988 and is in the process of seeking consensus and approval from the appropriate parties . We understand that the final closure plan has been prepared by Earth Technology and submitted to the RWQCB and that the County is in the process of reviewing it with the Regional Board and other affected parties . The final cover project will encompass an area of about 300 acres . The cover is envisioned to consist of six feet of materials including an initial 2 feet of 10-4 cm/sec . material , 2 feet of 10-5 cm/sec. material , and one to two feet of final cover which may be a mix of soil and sludge to enable grass or trees to grow. (The minus refers to the permeability expressed as the exponent of the base ten expressed in centimeters/second. Clay generally has a 10-6 cm/sec. permeability. ) -31- Another factor which must be considered in the final closure plan, is the need of Genstar who will be operating an energy recovery program using the methane gas generated at the site. Genstar has specified that they need to have two feet of base to work with before they can effectively begin their operation. They also have to have this layer in place to put in their wells . Genstar believes they can begin once about 60-70 acres have been covered with the two feet of final cover. Thus , scheduling of this project must be factored into any closure plan which suggests an accelerated cover project for the area in question. CSDOC has previously offered technical support on the use of sludge as an agricultural and soil amendment in the final cover at Coyote. CSDOC has also provided information developed by EPA on the use of sludge mixed with soil as a landfill cover. EPA had specified a 1 :1 mix and an application rate of 1600 cubic yards per acre. This would mean a total of up to 480,000 yards of sludge might be applied. This would be equivalent to the production of about 1173 days (assuming 409 annual average yards per day which is now the average going to Coyote) . Clearly, there is plenty of sludge available which could be used beneficially in the Coyote closure in accordance with terms for moisture content of sludge and the application methods established by the appropriate parties . CSDOC will continue to support any efforts to reuse sludge and is prepared to respond to requests for assistance. Technical assistance can be provided by the Districts to the County and other appropriate parties in completing the work necessary to incorporate sludge into the closure plan. Such assistance could include but not be limited to the following: o preparation of feasibility report; o demonstration project (on a portion of fill ) ; o design of closure improvements that incorporate sludge; -32- o provision of sewage facilities for accepting leachate and/or site runoff during and after closure operations; o demonstration project for final vegetative cover (golf course) and permanent soil amendment project (CSDOC sludge could be used on golf course for its life. This would be a positive step in recognizing the benefits of sludge reuse. ) Such a cooperative program can be anticipated to be beneficial to all parties , and the Districts would encourage implementation of such a program on a long- term basis at all existing landfills and extend it to other sites in the future. COMPLIANCE WITH CONDITIONS OF BEE CANYON MOU As discussed previously, included in the Memorandum of Understanding (MOU) between the County of Orange and the City of Irvine are several provisions concerning co-disposal at Bee Canyon Landfill . The Districts endorse the provisions of that MOU, and would propose to proceed in a manner consistent with its terms and conditions . Moreover, the 1985 agreement between the Irvine Ranch Water District and CSDOC recognized the mutual benefits to the community of Irvine as well as the community-at-large of forming new Sanitation District No. 14 to resolve Irvine's sewerage needs by allowing the conveyance of sewage and industrial waste to the CSDOC regional treatment and disposal facilities in Fountain Valley and Huntington Beach, and the reciprocal benefit of continuing co-disposal of the communities ' wastewater residuals at Coyote and Bee Canyons. The first step in the process is submittal of the Application for Facility Permit/Waste Discharge (Form 200) to the Regional Water Quality Control Board. It is understood that the County intends to file its application sometime in April , 1987. This is one of the most important steps in the process and as mentioned previously the Districts strongly suggest that the County, when submitting its application to the RWQCB for Bee Canyon , check Item IV.A, -33- indicating potential future sewage sludge disposal , with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact Report in accordance with the MOU. This would avoid delays and duplication of regulatory hearings . The Districts and -County would have to work closely together and with other appropriate parties in processing the application with the RWQCB and in completing the environmental work . As also discussed in preceding sections , it would seem appropriate that the Districts be designated the Lead Agency for CEQA purposes . Assuming the program of utilizing sludge with landfill closures is implemented, a schedule for preparation of the EIR as heretofore outlined based on starting it after Bee Canyon has opened would have similar time frames to that shown in Figure 2, but completion would be February, 1989, based on a May 1988 Notice of Preparation. The following sections discuss other specific conditions of the MOU which are relevant to the disposal of sludge and would be addressed in the EIR. Toxicity The requirement contained in A(2) of the MOU Agreement states that "all sludge to be dumped will be treated so as to achieve a toxicity content no greater than other materials which may be lawfully disposed of in the landfill (Class III ) " . Sludge will be tested to confirm compliance with this provision. Under the terms of the MOU, the City of Irvine is to receive copies of all toxicity reports on sludge to be disposed of at Bee, as required by State and Federal regulatory agencies . The Districts ' environmental consultant has recommended that CAM testing should be performed monthly at each plant (composite samples ) for a one year period to establish baseline levels (24 tests in a year) . This will supplement the priority pollutant analyses done under the present NPDES permit issued jointly by EPA and the RWQCB. -34- Technological Advancements The MOU states that the need for leachate collection and removal systems (LCRS) are to be determined by the RWQCB. Since Subchapter 15 had not been finalized at the time the MOU was signed, it was stated that new technology -will be explored and implemented. The Districts have a long and exemplary track record of researching and implementing new technology and intend to continue that practice. The Districts understand the County is studying this issue and the Districts are willing to provide assistance to the County in fulfilling any additional requirements which may be associated with co-disposal . (Also see previous section on CSDOC participation in Bee Canyon leachate control system and following section on landfill leachate and landfill gas energy recovery system waste disposal to CSDOC sewerage system to enhance groundwater protection. LANDFILL LEACHATE AND LANDFILL GAS ENERGY RECOVERY SYSTEM WASTE DISPOSAL TO CSDOC SEWERAGE SYSTEM TO ENHANCE GROUNDWATER PROTECTION The groundwater control plan is an important issue, and the Districts understand the County has initiated a Fast Track Program with the hiring of Converse Environmental to look at all alternatives and begin design on the most feasible project as soon as possible with construction to begin soon. Preliminary evaluation has indicated that a slurry trench and bentonite liner at the toe of the fill combined with extraction wells may be appropriate. Once the groundwater is collected, it will most likely have to be removed. Thus ongoing disposal via the Sanitation Districts ' sewer system appears to be a viable alternative that should be reviewed and considered. In addition, the County has been very progressive in proceeding with implementation of waste to energy systems to utilize the landfill methane gas produced for co-generation of electricity. These installations result in liquid -35- wastes in the form of boiler and cooling tower blowdown, D.I . system residuals and-condensate that, logically, could best be disposed of via the Sanitation Districts ' sewer system. The Districts propose to work with the County to develop a plan, consistent with their industrial waste and groundwater protection policies , to assist the County in disposing of the wastes from their landfill leachate control and co-generation systems to the Districts ' sewers. IMPLEMENTATION It is the Districts ' understanding that the County of Orange has not yet finalized a schedule identifying the time frames or activities which will be followed in filing the applications for Bee Canyon. It is suggested that the County and Districts initiate formal joint planning and other appropriate measures to implement the recommendations set forth herein . It is further suggested that meetings be held no less frequently than monthly to coordinate and track progress on preparing technical reports in order that we may support permit filings so that sludge disposal at Bee Canyon is not precluded. The Districts will also prepare the Environmental Assessment and EIR that will be needed to secure approval for sludge disposal pursuant to the Memorandum of Understanding. �A -36- REFERENCES California Administrative Code, 1984. Title 23 Waters, State Water Resources Control Board, Subchapter 15, Dischargers of Waste to Land. Adopted October 19, 1984. California Administrative Code, 1978. Title 14 Solid Waste Management Board, Chapter 3 Minimum Standards for Solid Waste Handling and Disposal . California Administrative Code, 1980. Title 14 Solid Waste Management Board, Chapter 4 Conformance of Solid Waste Facilities to County Solid Waste Management Plans . California Administrative Code, 1980. Title 14 Solid Waste Management Board, Chapter 5 Enforcement of Solid Waste Standards and Administration of Solid Waste Facilities Permits . California Department of Health Services , 1983. Manual of Good Practice for Land Spreading of Sewage Sludge. Sanitary Engineering Branch. April . Camp Dresser & McKee, 1984. A Comparison of Studies of Toxic Substances in POTW Sludges . Prepared for U.S. EPA Office of Water Regulations and Standards, Contract No. 68-01-6403, August. County of Orange, 1984. Final Draft-Orange County Solid Waste Management Plan. County General Services Agency Waste Management Program Office. June. County of Orange, 1976. Project Report and Draft Environmental Impact Report for Bee and Round Canyons Area Disposal Station (EIR-018) . Prepared by Environmental Management Agency, Environmental Services Division for County General Services Agency Solid Waste Management Division. July 20. County of Orange, Board of Supervisors , 1979. Resolution No. 79-1409, Certification of Final EIR for Bee Canyon Sanitary Landfill Site. September 25. County Sanitation Districts of Orange County, 1983. Sludge Disposal Alternatives-Short and Long-Term. Preliminary Study Information for Joint Boards of Directors Meeting, November 29, 1983. County Sanitation Districts of Orange County, 1984. Presentation to the RWQCB Regarding Sludge Solids to Coyote Canyon Landfill , May 9, 1984. Huitric, Ray, et. al , 1979. In-place Capacity of Refuse to Absorb Liquid Wastes . Presented at the Second National Conference on Hazardous Materials Management held February 27-March 2, 1979 at San Diego, California. Huitric, R. L. , et. al . (undated) . Moisture Retention of Landfilled Solid Wastes (Obtained from LA/OMA files ) . Lockman & Associates/PRC Toups Corporation, et. al ., 1979. Bee and Round Canyons Landfill Disposal Station Environmental Impact Report (Final ) . March. Maguin , S. R., (undated) . Land Disposal of Sludge (Obtained from LA/OMA files ) . Tchobanoglous , G., et . al ., 1979. Solid Wastes , McGraw-Hill Book Company. U.S. Environmental Protection Agency, 1985. Summary of Environmental Profiles and Hazard Indices for Constituents of Municipal Sludge: Methods and Results. Office of Water Regulations and Standards , July. U.S. Environmental Protection Agency, 1977 . Environmental Assessment of Subsurface Disposal of Municipal Wastewater Treatment Sludge. (Report SW-547c) . U.S. Environmental Protection Agency, 1984. Use and Disposal of Municipal Wastewater Sludge. Environmental Regulations and Technology . EPA-625/10-84-003, September. U.S. Environmental Protection Agency, 1985. Seminar Publication--Protection of Public Water Supplies from Groundwater Contamination. Center for Environmental Research, EPA/625/4-85/016. U.S. Environmental Protection Agency, 1985. Estimating Sludge Management r" Costs. Office of Research and Development, Water Research Engineering } Laboratory. EPA/625/6-85/010, October. E Results of the County Sanitation Districts of Orange County, California Industrial Pretreatment Program ITATlp,. b elt n O I � z O� tA Olne.tfE� L I I ORANGE COUNTY SANITATION DISTRICTS 10844 ELLIS AVENUE FOUNTAIN VALLEY, CALIFORNIA 92708 (714) 540-2910 -VAS. !iLEM ,A Or- ORANGE ORANGE COUNTY SANITATION DISTRICTS' SUCCESSFUL INDUSTRIAL PRETREATMENT PROGRAM • ORDINANCE PREPARED IN COOPERATION WITH REPRESENTATIVES FROM INDUSTRY, MANUFACTURERS ASSOCIATIONS AND CHAMBERS OF COMMERCE e FOUR-PHASE IMPLEMENTATION APPROACH PHASE I (JULY 1, 1976) - REQUIRED "GOOD HOUSEKEEPING" PRACTICES BY INDUSTRY. ALLOWED TIME FOR SOURCE CONTROL PLANS TO BE DEVELOPED PHASE II (JULY 1, 1978) - REQUIRED INSTALLATION OF PRETREATMENT FACILITIES WITH LIMITS TO MEET CALILFORNIA OCEAN PLAN REQUIREMENTS PHASE III (JULY 1, 1983) - REQUIRES ADDITIONAL PRETREATMENT FACILITIES BY INDUSTRY TO MEET ALL APPLICABLE REQUIREMENTS PHASE IV (APRIL 27, 1984 AND THEREAFTER) - ENFORCEMENT OF EPA CATEGORICAL PRETREATMENTS STANDARDS WHEN IMPLEMENTED BY EPA ® ACTIVE ENFORCEMENT PROGRAM BY DISTRICTS' INDUSTRIAL WASTE DIVISION FREQUENT SAMPLING OF INDUSTRY BY DISTRICTS ' PERSONNEL SAMPLE AND EVALUATION PROGRAMS ENFORCEMENT COMPLIANCE SCHEDULE AGREEMENTS CEASE AND DESIST ORDER ' PERMIT REVOCATION ' CIVIL OR CRIMINAL COMPLAINTS CPT:AS1 3/ 86 CGUJ SAKI IATIUN ISIST71CrS 07 ANGE COUNTY, CALIFORNIA INDUSTRIAL DISCHARGE LIMITS, mg/l (Source Control Program) Electroplating* Limitations EFFECTIVE EFFECTIVE EFFECTIVE CONSTITUENT July 1, 1976 July 1, 1978 July 1, 1983 April 27, 1984 Arsenic 2.0 2.0 2.0 2.0 Cadmium 5.0 3.0 1.0 1.0 Chromium (total ) 6.0 2.0 2.0 2.0 Copper 10.0 4.0 3. 0 3.0 Lead 2.0 2.0 2.0 0.6** Mercury 0.03 0.03 0.03 0.03 Nickel 10.0 10. 0 10.0 4. 1** Silver 5.0 5.0 5.0 1. 2** Zinc 15.0 10.0 10.0 4.2** Cyanide (total ) 10.0 5.0 5.0 Cyanide (free)*** 1.0 1.0 1. 0 1.0 PCB's & Pesticides 0.02 0.02 Total Toxic Organics (as defined by EPA) 0. 58 0.58 Total Sulfide 5.0 5.0 Dissolved Sulfide 0. 5 0.5 Oil and grease of mineral , petroleum origin 100.0 100.,0 * There are categorical limitations prescribed by EPA for other types of industry. This Is an example of a blending of the [PA limitations with CSUUC. Whichever reyulatlon is more stringent would apply. ** Environmental Protection Agency categorical standards for electroplaters one day maximum limits. Fffective April 21, 19114. **"The term "free cyanide" shall mean those cyanides amenadable to chlorination as described in the Annual (look of AS{M Slaodards, 1912, Slandard 1) 203642 Mc!thod II., page 553. CPf:ASI EFFLUENT CADMIUM 900 1983 Ocean Plan Limitation 800 100 90 - 80 CSDOC Actual Discharge 70 60 — 50 — 40 30 20 10 0 75 7 6 77-78 79-80 81 -82 83-84 85-86 Date 1500 COPP ' R 1983 Ocean Plan Limitation 1400 700 600 - CSDOC Actual Discharge 500 v ' v .a — 400 rnit lrTlii::itl+�+ 300 200 100 �� 75--76 71-78 79--80 81 -82 83-84 85-86 Date EFFLUENT LED 2280 1983 Ocean Plan Limitation 2260 260 240 220 200 1985 Ocean Discharge PErrTlit Umit>>ticn 180 _. - -- -- .p 160 1 ���CSSDOC Actual Discharge 120 20 - 100 80 60 40 - 20 - 0 75-76 77—78 79--80 81-82 83-84 85-86 Date EFFLUENT NICKEL 1983 Ocean Plan Limitation 5680 230 q 220 210 \ 200 190 180 170 -°0 160 \ n 150 �j — 140 130 SDOC Actual Discharge 120 110 100 90 80 70 60 — 7--- 75-76 77-78 79-80 81 —82 83-84 85-86 Date EFFLUENT - �-��| | | [-K |�- SILVER L_[- |- L-�JL_| \] | l]U 1983 Ocean Plan Limitation 40 30 � n � \` m � _ 20 10 O 75-78 77-78 79-80 81 -82 83-84 85-86 Dote EFFLUENT ZINC 5 7 1983 Ocean Plan Limitation 1 0.9 \ t 0.8 a � o 0.7 v o CO a 0.6 1985 Occ.urn Dischorr�e P rrriit L irnitation 0.5 CSDOC Actual Discharge 0.4 \� 0.3 0.2 0.1 75-76 77-78 79-80 81 —82 83-84 85-86 Date Effluent Biochemical oxygen Demand 240 230 220 210 200 Ocean Discharge Permit Limitation 190 180 \ 170 160 150 140 — CSDOC Actual Discharge 130 120 110 100 90 80 70 75-76 77-78 79-80 81 -82 83-84 85-86 Date Effluent Total Suspended Solids 200 190 180 170 160 Ocean Dischar e Permit Limitation 150 140 130 120 110 rn 100 CSDOC Actual Discharge 90 80 70 60 50 40 30 20 10 0 77-78 79-80 81 -82 83-84 85-86 Date ATTACHMENT 2 CEQA EXCERPTS Article 11. Types of EIRs General 15160. This article describes a number of examples of variations in EIRs as the documents are tailored to different situa- tions and intended uses . These variations are not exclusive. Lead Agencies may use other variations consis- tent with the Guidelines to meet the needs of other circumstances. All EIRs must meet the content requirements discussed in Article 9 beginning with Section 15120. Note: Authority cited : Sections 21083 and 21087 , Public Resources Code; Reference: Sections 21061 , 21100 , and 21151, Public Resources Code. Discussion: This section describes the contents of this article and explains that the types of EIRs described here are not the only possibilities. Project EIR 15161. The most common type of EIR examines the environmental impacts of a specific development project. This type of EIR should focus primarily on the changes in the environ- ment that would result from the development project. The EIR shall examine all phases of the project including s. planning, construction, and operation. Note: Authority cited: Sections 21083 and 21087 , Public Resources Code; Reference: Sections 21061 , 21100, and 21151, Public Resources Code. Discussion: This section is necessary for the clarity and completeness of this article and to show how this type of EIR differs from the other types discussed in this article. Subsequent EIR 15162. low (a) Where an EIR or Negative Declaration has been prepared, no additional EIR need be prepared unless: (1) Subsequent changes are proposed in the project which will require important revisions of the previous EIR, or Negative Declaration due to the involvement of new significant environmental impacts not considered in a previous EIR or Negative Declaration on the project; (2) Substantial changes occur with respect to the circumstances under which the project is undertaken, such as a substantial deterioration in the air quality where the project will be located, which will require important revisions in the previous EIR or Negative Declaration due to the involvement of new significant environmental impacts not covered in a previous EIR or Negative Declaration; or (3) New information of substantial importance to the project becomes available, and (A) The information was not known and could not have been known at the time the previous EIR was certified as complete or the Negative Declaration was adopted, and (B) The new information shows any of the following: 1. The project will have one or more significant effects not discussed previously in the EIR; 2. Significant effects previously examined will be substantially more severe than shown in the EIR; 3. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more sig- nificant effects of the project; or 4. Mitigation measures or alternatives which were not previously considered in the EIR would sub- stantially lessen one or more significant effects �- on the environment. (b) If the EIR or Negative Declaration has been completed but the project has not yet been approved, the Lead Agency shall prepare or cause to be prepared the subsequent EIR before approving the project. "^ (c) If the project was ---Moved prior to the occurrence of the conditions described in subsection (a) , the subsequent EIR shall be prepared by the public agency which grants the next discretionary approval for the project. In this situation no other Responsible Agency shall grant an ap- proval for the project until the subsequent EIR has been completed. Note: Authority cited : Sections 21083 and 21087 , Public Resources Code; Reference: Section 21166, Public Resources Code. Formerly Section 15067. Discussion: This section implements the requirements in Section 21166 of CEQA which limit preparation of a subsequent EIR to certain situations. This section provides interpretation of the three situations in which the statute requires preparation of a subsequent EIR. These interpretations are necessary to add certainty to the process. Subsections (b) and (c) explain which agency would have responsibility for preparing a subsequent EIR under dif- ferent circumstances. A subsequent EIR must, of course, receive the same circulation and review as the,previous EIR. Supplement 15163. to an EIR (a) The Lead or Responsible Agency may choose to prepare a supplement to an EIR rather than a subsequent EIR if: (1) Any of the conditions described in Section 15162 would require the preparation of a subsequent EIR, and (2) Only minor additions or changes would be necessary to make the previous EIR adequately apply to the project in the changed situation. (b) The supplement to the EIR need contain only the infor- oration necessary to make the previous EIR adequate for the project as revised. (c) A supplement to an EIR shall be given the same kind of notice and public review as is given to a draft EIR under Section 15087. - (d) A supplement to an EIR may be circulated by itself without recirculating the previous draft or final EIR. (e) When the agency decides whether to approve the project, the decision-making body shall consider the pre- vious EIR as revised by the supplemental EIR. A finding under Section 15091 shall be made for each significant effect shown in the previous EIR as revised. Note: Authority cited : Sections 21083 and 21087, Public Resources Code; Reference: Section 21166, Public Resources Code. Formerly Section 15067.5. Discussion: This section provides a short-form method where only minor additions or changes would be necessary in the previous EIR to make that EIR apply in the changed situation. The section also provides essential interpretations of how to handle public notice, public review, and circulation of the supplement. Addendum 15164. to an EIR (a) The Lead Agency or a Responsible Agency shall prepare an addendum to an EIR if: (1) None of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred; (2) Only minor technical changes or additions are necessary to make the EIR under consideration adequate under CEQA; and (3) The changes to the EIR made by the addendum do not raise important new issues about the significant effects on the environment. (b) An addendum need not be circulated for public review but can be included in or attached to the final EIR. (c) The decision-making body shall consider the addendum with the final EIR prior to making a decision on the project. Note: Authority cited : Sections 21083 and 21087 , Public Resources Code; Reference: Section 21166, Public Resources Code. Discussion: This section is designed to provide clear authority for an addendum as a way of making minor corrections in EIRs without recirculating the EIR. The addendum is the other side of the coin from the supplement to an EIR. 580 Er F-I UD\1 CHROMIUM 1983 Ocean Plan Limitation 560 300 280 — 260 240 220 200 1985 Oce-an Discharge. Permit Limitation 0 160 140 120 CSDOC Actual Discharge '1100 80 60 40 - 20 0 75-76 77--78 79-80 81--82 83-84 85-86 Date