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HomeMy WebLinkAbout1988-05-04 Select Committee (Bee Canyon)May 4, 1988 Executive Committee Report (2) Issuance of industrial waste permits to all commercial and industrial users within each project area, and levy of a user fee on residences within each project area (3) Direct negotiations to discuss costs and select an appropriate alternative on a project -by -project basis The General Counsel advised the Committee that Section 33676 of the Health & Safety Code provides that any affected taxing agency (i.e., the Districts), may elect to be allocated a portion of the 2% incremental tax revenue allowed annually by Proposition 13 in addition to the portion of ad valorem taxes which are presently received. In effect, this Section would provide that in the event no pass -through agreement is negotiated relating to the tax increment, that the District would, in addition to the portion of taxes presently received, also receive a portion of the increased revenue attributable to the increased assessed value of the taxable property in the project area before such monies are allocated to the Redevelopment Agency debt fund. The General Counsel reviewed the enclosed memorandum and draft resolution electing to receive the tax increment pass -through for the Orange County Neighborhood Development and Preservation Project (the next scheduled redevelopment project under consideration that significantly affects the Districts) pursuant to the provisions of Health and Safety Code Section 33676. Staff recommended that the Directors consider modifying the Boards' redevelopment agency policy to incorporate the provision of electing to receive such tax increment pass-throughs for redevelopment projects under Section 33676. It was noted that if such a policy is adopted a separate resolution would be required for each redevelopment project as they are submitted for consideration and hearing in the future. The Committee continued consideration of amending the redevelopment agency policy until their next meeting. However, because time constraints would not allow deferral of an action on the pending Orange County Development Agency project, the Executive Committee recommends adoption of the Resolution Electing Tax Increment Pass -Through for the Orange County Neighborhood Development and Preservation Project. 3) Status Report and Recommendation on Districts' Solids Residuals Management Program. A. Bee Canyon Landfill Staff reviewed the enclosed Status Report and Recommendations on Districts' Solids Residuals Management Program, and updated the Committee on developments with regard to the proposed new Bee Canyon Landfill. Continuation of the cooperative program with the County of Orange for co -disposal of sludge and refuse at County landfills is the preferred disposal option previously selected by the Boards. Although the Districts are continuing to pursue other disposal alternatives and, in fact, are in the process of entering into contracts with several private firms for recycling sludge, if for no other reason, a landfill back-up disposal option is needed in case other disposal alternatives disappear. -3- May 4, 1988 Executive Committee Report Historically, landfill disposal is the most reliable method. The logical long-term co -disposal site is the County's new Bee Canyon Landfill in Irvine. There are several reasons for this, including that it is the replacement for Coyote Canyon, where the majority of our sludge is now taken (Coyote Canyon Landfill, where Districts' sludge is now taken is now scheduled to begin closure in March 1989); it will have adequate refuse to meet the required mix ratios; it is remote, yet centrally located; it is the most reliable, cost-effective site; it is a new landfill and, thus, could be engineered to accept waste under the most favorable environmental conditions; and Irvine's and Orange County's taxpayers would benefit from the annual tipping -Pee paid by the Districts, estimated to be over $3,000,000 per year (based on the proposed new fee). Disposal of sludge at the County's new Bee Canyon landfill is precluded until CEQA and other requirements are satisfied in accordance with a Memorandum of Understanding (MOU) between the County and Irvine. The Districts have been aware of the MOU all along, have fully supported its provisions, and have proposed to proceed in a manner consistent with its terms and conditions. The first step in obtaining an operating permit from the Regional Water Quality Control Board (RWQCB) for Bee Canyon landfill is the submittal of an "Application for Facility Permit/Waste Discharge (Form 200)" to the RWQCB. In order to assure that the RWQCB will consider the Bee Canyon application and issue the permit in a manner so as not to preclude sludge disposal at Bee Canyon some time in the future, the Districts proposed to the County in the March 1987 letter that when submitting its application to the RWQCB for Bee Canyon, the box on the application form indicating the potential for future sewage sludge disposal be checked, with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact Report in full satisfaction of the terms and conditions of the MOU between the County and Irvine. This is an important step in the process and would avoid future delays and duplication of regulatory hearings. It is also in keeping with the full spirit and intent of the MOU. Staff reported that they were still working with the County and the City of Irvine to work out an arrangement that would allow them to give favorable consideration to submitting the RWQCB application as requested by the Districts and that they would keep the Directors apprised. B. Authorizing Agreement with Pima Gro Systems for Reuse of Portion of Districts' Sludge Recognizing that the landfill situation is in a state of flux and could be significantly altered at any time, the Boards recently determined that it was in the Districts' best interests to implement multiple disposal/reuse programs. Accordingly, the Directors adopted a policy of implementing multiple solids residuals disposal and/or reuse options, under separate and various contractual arrangements deemed suitable, to maximize interim and long-term residuals management alternatives and ongoing reuse and disposal reliability. Under this policy, if one program ceased to be viable, for whatever reason, then the sludge volumes handled by that option could in all likelihood be transferred to one or more of the other programs. -4- May 4, 1988 Executive Committee Report Historically, landfill disposal is the most reliable method. The logical long-term co -disposal site is the County's new Bee Canyon Landfill in Irvine. There are several reasons for this, including that it is the replacement for Coyote Canyon, where the majority of our sludge is now taken (Coyote Canyon Landfill, where Districts' sludge is now taken is now scheduled to begin closure in March 1989); it will have adequate refuse to meet the required mix ratios; it is remote, yet centrally located; it is the most reliable, cost-effective site; it is a new landfill and, thus, could be engineered to accept waste under the most favorable environmental conditions; and Irvine's and Orange County's taxpayers would benefit from the annual tipping fee paid by the Districts, estimated to be over $3,000,000 per year (based on the proposed new fee). Disposal of sludge at the County's new Bee Canyon landfill is precluded until CEQA and other requirements are satisfied in accordance with a Memorandum of Understanding (MOU) between the County and Irvine. The Districts have been aware of the MOU all along, have fully supported its provisions, and have proposed to proceed in a manner consistent with its terms and conditions. The first step in obtaining an operating permit from the Regional Water Quality Control Board (RWQCB) for Bee Canyon landfill is the submittal of an "Application for Facility Permit/Waste Discharge (Form 200)" to the RWQCB. In order to assure that the RWQCB will consider the Bee Canyon application and issue the permit in a manner so as not to preclude sludge disposal at Bee Canyon some time in the future, the Districts proposed to the County in the March 1987 letter that when submitting its application to the RWQCB for Bee Canyon, the box on the application form indicating the potential for future sewage sludge disposal be checked, with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact Report in full satisfaction of the terms and conditions of the MOU between the County and Irvine. This is an important step in the process and would avoid future delays and duplication of regulatory hearings. It is also in keeping with the full spirit and intent of the MOU. Staff reported that they were still working with the County and the City of Irvine to work out an arrangement that would allow them to give favorable consideration to submitting the RWQCB application as requested by the Districts and that they would keep the Directors apprised. B. Authorizing Agreement with Pima Gro Systems for Reuse of Portion of Districts' Sludqe Recognizing that the landfill situation is in a state of flux and could be significantly altered at any time, the Boards recently determined that it was in the Districts' best interests to implement multiple disposal/reuse programs. Accordingly, the Directors adopted a policy of implementing multiple solids residuals disposal and/or reuse options, under separate and various contractual arrangements deemed suitable, to maximize interim and long-term residuals management alternatives and ongoing reuse and disposal reliability. Under this policy, if one program ceased to be viable, for whatever reason, then the sludge volumes handled by that option could in all likelihood be transferred to one or more of the other programs. -4- May 4, 1988 Executive Committee Report (2) Issuance of industrial waste permits to all commercial and industrial users within each project area, and levy of a user fee on residences within each project area (3) Direct negotiations to discuss costs and select an appropriate alternative on a project -by -project basis The General Counsel advised the Committee that Section 33676 of the Health & Safety Code provides that any affected taxing agency (i.e., the Districts), may elect to be allocated a portion of the 2% incremental tax revenue allowed annually by Proposition 13 in addition to the portion of ad valorem taxes which are presently received. In effect, this Section would provide that in the event no pass -through agreement is negotiated relating to the tax increment, that the District would, in addition to the portion of taxes presently received, also receive a portion of the increased revenue attributable to the increased assessed value of the taxable property in the project area before such monies are allocated to the Redevelopment Agency debt fund. The General Counsel reviewed the enclosed memorandum and draft resolution electing to receive the tax increment pass -through for the Orange County Neighborhood Development and Preservation Project (the next scheduled redevelopment project under consideration that significantly affects the Districts) pursuant to the provisions of Health and Safety Code Section 33676. Staff recommended that the Directors consider modifying the Boards' redevelopment agency policy to incorporate the provision of electing to receive such tax increment pass-throughs for redevelopment projects under Section 33676. It was noted that if such a policy is adopted a separate resolution would be required for each redevelopment project as they are submitted for consideration and hearing in the future. The Committee continued consideration of amending the redevelopment agency policy until their next meeting. However, because time constraints would not allow deferral of an action on the pending Orange County Development Agency project, the Executive Committee recommends adoption of the Resolution Electing Tax Increment Pass -Through for the Orange County Neighborhood Development and Preservation Project. 3) Status Report and Recommendation on Districts' Solids Residuals Management Program. A. Bee Canyon Landfill Staff reviewed the enclosed Status Report and Recommendations on Districts' Solids Residuals Management Program, and updated the Committee on developments with regard to the proposed new Bee Canyon Landfill. Continuation of the cooperative program with the County of Orange for co -disposal of sludge and refuse at County landfills is the preferred disposal option previously selected by the Boards. Although the Districts are continuing to pursue other disposal alternatives and, in fact, are in the process of entering into contracts with several private firms for recycling sludge, if for no other reason, a landfill back-up disposal option is needed in case other disposal alternatives disappear. -3- COUNTY SANITATION DISTRICTS April 28, 1988 STATUS REPORT AND RECOMMENDATIONS ON DISTRICTS' SOLIDS RESIDUALS MANAGEMENT PROGRAM of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O. BOX 8127 FOUNTAIN VALLEY, CALIFORNIA 92728-8127 (714) 962-2411 Staff has been keeping the Directors briefed on the Districts' Solids Residuals Management Plan, and the Boards have recently taken several actions relative to the ongoing implementation of the plan. This is a status report and recommendation for further actions. Background For many years the Districts have practiced landfill co -disposal of wastewater solids residuals (sludge) with municipal solid waste (trash) at the County's Coyote Canyon Landfill. In November 1983, after an extensive study of sludge disposal alternatives including private sector reuse/disposal, co -combustion and land and mechanical composting, the Boards selected continued landfill co -disposal as the preferred long-term sludge disposal alternative. As directed by the Boards pursuant to that policy determination, staff has been meeting regularly with Orange County's Waste Management Division staff regarding the long-term continuation of the County and the Sanitation Districts' cooperative program of managing metropolitan Orange County's waste disposal. As a result of this work, in March of 1987, a preliminary proposal was submitted to the Waste Management Division for joint planning and implementation measures to continue the program of integrated co -disposal of wastewater solids residuals and municipal solid waste on a long-term basis at County landfills. The enclosed copy of the transmittal letter summarizes the Districts' proposal. Bee Canyon As the letter points out, the logical long-term co -disposal site is the County's new Bee Canyon Landfill for several reasons including that it is the replacement for Coyote Canyon where the majority of our sludge is now taken and will have adequate refuse to meet the required mix ratios (Coyote is now scheduled to begin closure in March, 1989); it is remote yet centrally located; it is the most reliable, cost-effective site; it is a new landfill and, thus, could be engineered to accept waste under the most favorable environmental conditions, with or without sludge; and Orange County's taxpayers would benefit from the annual tipping fee paid by the Districts to the County estimated to be over $3,000,000 per year (based on the proposed new fee). As the Directors are aware, disposal of sludge at the County's new Bee Canyon landfill in Irvine is precluded until CEQA and other requirements are satisfied in accordance with a Memorandum of Understanding (MOU) between the County and Irvine. The Districts have been aware of the MOU all along, have fully supported its provisions, and have proposed to proceed in a manner consistent with its terms and conditions. We are extremely cognizant of the issues surrounding the opening and operation of the landfill and the potential sensitivities relative to sludge disposal and, in fact, for these reasons have advised County Solid Waste Management staff that no formal proposal for sludge co -disposal at Bee Canyon would be considered until after Bee Canyon is operating so as not to impede its opening. -1- However, the first step in obtaining an operating permit from the Regional Water Quality Control Board (RWQCB) for Bee Canyon landfill is the submittal of an "Application for Facility Permit/Waste Discharge (Form 200)" to the RWQCB. In order to assure that the RWQCB would consider the Bee Canyon application and issue the permit in a manner so as not to preclude sludge disposal at Bee Canyon some time in the future, the Districts proposed to the County in the March 1987 letter that when submitting its application to the RWQCB for Bee Canyon, the box on the application form indicating the potential for future sewage sludge disposal be checked, with the qualification that such disposal would be subject to completion of an Environmental Assessment and Environmental Impact Report in full satisfaction of the terms and conditions of the MOU between the County and Irvine. This is an important step in the process and would avoid future delays and duplication of regulatory hearings. Throughout our discussions with the County's staff they have indicated a willingness to proceed as outlined above. However, we have been advised just recently by the County Waste Management Program staff that they now do not intend to check the box on the RWQCB application form indicating the potential for future sludge disposal. Although the permit could presumably be amended at some time in the future for sludge disposal, it would certainly be a more difficult procedure and could prove extremely costly to both the County and the Districts for landfill retrofitting. Further, the County would lose the annual tipping fee paid to it by the Districts, estimated at approximately $3,000,000 per year. Current Sludge Disposal Practice/Policy Pursuant to the aforementioned policy, the Districts have been disposing of residual solids (dewatered sludge, grit and screenings) by use of landfills in Orange and Los Angeles Counties. The bulk (up to 75%) of our sludge is currently disposed of at Orange County's Coyote Canyon landfill in Irvine at a cost of approximately $19/ton (the County has advised us of its intent to raise the tipping fee from $10/ton to $15/ton which would increase the co -disposal cost to approximately $24/ton). Until recently the remainder (up to 25%) of our daily sludge production has been trucked to BKK, a private landfill in West Covina. The current BKK cost is $18.95/ton. However, as previously reported to the Directors, BKK has proposed a price increase to $38.75/ton (see separate discussion below). Although landfill co -disposal is the preferred long-term disposal alternative because it is generally the most reliable and least costly method, the Districts are continuing to pursue other viable long and short-term alternatives. Recognizing that the landfill situation is in a state of flux and could be significantly altered at any time, the Boards recently determined that it was in the Districts' best interests to implement multiple disposal/reuse programs. Accordingly, the Directors adopted a policy of implementing multiple solids residuals disposal and/or reuse options, under separate and various contractual arrangements deemed suitable, to maximize interim and long-term residuals management alternatives and ongoing disposal and reuse reliability. Under this policy, if one program ceased to be viable, for whatever reason, then the sludge volumes handled by that option could in all likelihood be transferred to one or more of the other programs. Although this practice would result in a range of costs depending on the option and the associated contractual arrangements it would provide for the maximum disposal reliability for the Districts' ever-increasing volume of sludge. Current disposal methods range from approximately $19/ton to around $25/ton and potentially feasible near term options range anywhere from $25/ton to about $35/ton which are the going rates for most Southern California POTW's. -2- Accordingly, the Districts have entered into contracts with two firms, Recyc, Inc. and L. Curti, Inc. in San Bernardino County that now take up to 25% of our sludge and process it at a cost of between $19 and $21 per ton. A third contract has been authorized with Chino -Corona Farms, Inc., for a one-time demonstration project to directly incorporate 80,000 yards (about six months production) into agricultural land in south Orange County for a citrus grove at a cost of approximately $24/ton; however, that project is currently awaiting the necessary permits. The present alternative to the above described current practices for disposing of the 700+ tons of sludge a day that we produce would be for the Districts to compost the material to a solids content of 50% or more. It could then be hauled to an in -county landfill without the restrictions of the Regional Water Quality Control Board for landfill co -disposal (22�i % solids content and 10:1 mix with trash). The estimated cost to the Districts for on -site (at the two treatment plants) composting and landfill disposal would be $42.00/ton. The estimated cost for off -site composting and disposal is estimated at $52.00/ton. In addition to the higher costs there would be some operational drawbacks to on -site composting. However, one advantage that would accrue to Orange County for in -county disposal of the additional sludge now trucked out of the county would be an increased annual payment of over $750,000 by the Districts in tipping fees to the Orange County Solid Waste Management Fund. Requested Price Adjustment by BKK re Agreement for Sludge Disposal The staff has previously briefed the Committee on the requested price adjustment by BKK relative to the agreement with the Districts for hauling and disposing of a portion of our sludge at BKK's private landfill in West Covina. The existing contract has a provision for price escalation based on the Consumer Price Index or, if BKK can establish that direct operational costs over which it has no control exceed the CPI, a higher increase can be negotiated. BKK, the owner and operator of the landfill, has requested a 105% increase in the price, including trucking and disposal, from $18.95/ton to $38.75/ton. A current dispute between the City and County of Los Angeles is exacerbating the issue and may result in an action by the County which would preclude BKK from accepting any waste from Orange County. If this occurs, it could pose some operating and sludge disposal difficulties for the Districts. The Executive Committee has previously directed staff to continue to negotiate with BKK to attempt to reach an agreement and has provided guidelines for acceptable terms. Staff and counsel are continuing those negotiations but have yet to come to an agreement. We are hopeful that a much more favorable price than requested by BKK can be agreed to. If an agreement is reached, within the parameters set by the Committee prior to the Committee meeting, staff will submit it to the Directors for consideration. Recommendation to Authorize Agreement with Pima Gro Systems, Inc., for Reuse of Portion of Districts' Sludge In accordance with the above described multiple disposal/reuse policy, staff has received a proposal from Pima Gro Systems, Inc. of Oklahoma City, Oklahoma, (copy enclosed) for the removal and reuse of sewage sludges from Plants 1 and 2. Pima Gro Systems presently has approval for beneficial reuse of sewage sludge on 79 different sites totaling over 11,000 acres. These sites are located in the Colorado River region of California, and in Arizona in the Yuma area. They have successfully land -applied sludge from Pima County, Arizona for over four years -3- with a current volume of 7,500 tons per week. Pima Gro has received a permit from the California Colorado River Regional Water Quality Control Board for the agricultural use of sewage sludge on some 37 sites totaling over 5,000 acres of farm land located southeast of the Salton Sea in the Imperial Valley. Pima Gro Systems, Inc. proposes to haul the digested, dewatered sludge from the treatment plants directly to these permitted farm lands and incorporate the sludge directly into the soil for such crops as Bermuda grass, small grain, sugar beets, alfalfa and cotton. The application of sludge will be done under the stringent permit conditions as set forth by the Regional Water Quality Control Board and will follow the EPA guidelines for direct application of sewage sludge for beneficial use on agricultural land. Pima Gro proposes to haul and reuse a minimum guaranteed quantity of 600 tons per week (about 17% of our production) for the price of $33.50 per wet ton. Although the volume initially proposed to be taken by Pima Gro will be relatively small, if the need arises the firm has indicated that it could handle the Districts' total daily sludge production. It is therefore recommended that the General Manager be authorized to negotiate and execute an agreement, in form approved by the General Counsel, with Pima Gro Systems, Inc., for the disposal/reuse of residual solids at a cost not to exceed $33.50 per ton from Plants 1. and 2. If a long-term (more than one year) agreement is negotiated it will include a provision for annual price adjustments as is standard practice in our other agreements. The estimated annual costs, based on a minimum guarantee of 600 tons per week ($1,045,299) will be partially offset by reduced landfill co -disposal costs. -4- COUNTY SANITATION DISTRICTS OF ORANGE COUNTY, CALIFORNIA P.O. BOX 8127, FOUNTAIN VALLEY, CALIFORNIA 92728-8127 s'^i19" 10844 ELLIS, FOUNTAIN VALLEY, CALIFORNIA 92708-7018 "'NGE COS"`y (714) 962-2411 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 Program of the County Waste Management Dear Frank: and Expansion of the Cooperative and the Sanitation Districts for 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 (7141 962-241 1 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. Following 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 92728-8127 (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 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 Orange 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. BOX 8127 FOUNTAIN VALLEY, CALIFORNIA 92728-8127 (7141 962-241 1 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 CSDOC 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 completing 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 of ORANGE COUNTY. CALIFORNIA — 10844 ELLIS AVENUE P.O. BOX 8127 FOUNTAIN VALLEY, CALIFORNIA 92728-8127 (7141 962-241 1 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 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 cf 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 0IS I RICTS of ORANGE COUNTY, CALIFORNIA 10844 ELLIS AVENUE P.O. BOX 8127 FOUNTAIN VALLEY. CALIFORNIA 92728-8127 (7141962-2411 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. JWS/pk Enclosures: "Evaluation and Recommendation for Continued Co -Disposal of Wastewater Residuals and Municipal Solid Waste in Orange County" PIMA GRO SYSTEMS, INC. AGRICULTURAL REUSE SPECIALISTS 2305 R uthrauff Rd. Tucson, AZ 85705 Phone (602) 293-4472 P. O. Box 800 P. O. Box 18872 Rillito, AZ 85654 Oklahoma City, OK 73154 Phone (602) 791-9578 Phone (405) 557-0100 PLEASE RESPOND TO THE OKLAHOMA CITY OFFICE April 14, 1988 Mr. Bill Clark General Superintendent Orange County Sanitation District P. O. Box 8127 10844 Ellis Ave. Fountain Valley, CA 92728-8127 RE: Sludge Removal and Utilization Plant #2 Dear Mr. Clark: Pima Gro Systems, Inc. is interested in providing a sludge removal and disposal service for the County Sanitation Districts of Orange County. We have met and discussed Pima Gro Systems, Inc. capabilities in providing an ultimate disposal option for sludge through agricultural utilization. Pima Gro Systems, Inc. presently has approval for beneficial reuse of sewage sludge on 79 sites totaling 11,044.3 acres. Approved sites are located in the Colorado River Region (Region 7) and in Arizona in the Yuma area. Pima Gro Systems, Inc. has successfully land applied sludge from Pima County Arizona for 51 consecutive months with a current volume of 7,500 wet tons per week. You may consider this communication as a proposal for the removal, transportation and ultimate disposal of anaerobically digested sewage sludge through beneficial reuse on agricul- tural land. The following conditions are presented for your consideration: 1. Sludge source - plant 42 2. Minimum quantity guaranteed - 600 wet tons per week. 3. Price for all services - $33.50 per wet ton (ton hauled) . 4. Basis for payment - ton hauled as determined by scales. Mr. Bill Clark April 14, 1988 Page 2 5. Agreement duration - one year. 6. Start work within 45 days from notice to proceed. 7. Billing period - once every two weeks. 8. Hauling schedule will be as needed by the District. Hauling initially is planned for 5 days per week, daylight hours. 9. Pima Gro Systems, Inc. will conduct all aspects of the program in a professional manner at all times. Specific items include, but are not limited to: A. Spare no reasonable measures to eliminate over- taxing the patience of residences adjacent to plant ##2. B. No spills. C. Full and prompt compliance with all regulatory requirements. Pima Gro Systems, Inc. will submit the documentation to the District necessary for verifying regulatory compliance. D. Pima Gro Systems, Inc. will keep the district informed as to beneficial reuse site locations and will grant access for the purpose of monitoring reuse operations involving District sludge. 10. Pima Gro Systems, Inc. will maintain insurance in a customary amount. A certificate of insurance will be provided to the district. Please call me at (405) 557-0100 if you have any questions, require additional information or care to discuss my proposal. Regards, WILSON E. NOLAN WEN/ras/pgs2memo.apr PIMA GRO SYSTEMS, INC. AGRICULIURAL REUSE SPECIALISTS