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.
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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