Honorable Judge William L. Gordon
Presiding Judge, Santa Barbara County Superior Court
1100 Anacapa Street
Santa Barbara, California 93121

Subject: Grand Jury Report Titled
"Environmental Regulation of Tajiguas Landfill"

Public Works would like to thank the Grand Jury for the findings and recommendations included in the subject report. Public Works would also like to thank the Grand Jury for the commendation section in the report in which the Grand Jury acknowledges the hard work of the people responsible for the operation of the landfill and their efforts at environmental compliance.

FINDING 1: There are four monitoring wells (MW) in a line down gradient (down slope) from the landfill site. In order to detect the direction of the plume of contaminated leachate, wells to monitor ground water quality should be in a triangular formation. A third well is needed to triangulate with the southerly two wells, MW #3 and MW #15.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 1: Install another well to complete the triangle.

PUBLIC WORKS RESPONSE: The recommendation will be analyzed further. Although triangulation is necessary to achieve the desired outcome, an existing well in the immediate area could be used as the third well to determine the groundwater gradient and direction of flow. Public Works will try to obtain an easement from the property owner to enter the property for the purpose of measuring the water level in the well. If an easement can not be obtained, Public Works will install a third well to triangulate with the southerly two wells to determine the groundwater gradient and direction of flow. Public Works proposes to complete the well triangulation within six months, by December 1997.

FINDING 2: The collection trench does not contain all of the leachate; thus some is escaping from the site.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 2: Continue to find improved methods to prevent the leachate from leaving the landfill site. The well described in Recommendation 1 above will help Health Care Services Department track movement of leachate.


PUBLIC WORKS RESPONSE: The recommendation will be implemented. Public Works is currently analyzing several options to improve the recovery of landfill impacted groundwater from leaving the site. Public Works proposes to test four options to improve the recovery of landfill impacted groundwater. Each option will be evaluated and implemented in succession until satisfactory performance of the collection system is obtained. The options will be tested in the following order with the first two options taking four months to evaluate and install:

· Lower pumps and increase the amount of water being captured by the existing collection trench.
· Install two groundwater extraction wells down gradient of the collection trench.
· Install landfill gas collection and recovery system in accordance with Federal EPA and State Air Resources Board requirements. The leachate may be a result of landfill gas impacting the ground water.
· Install subsurface cutoff barrier and groundwater extraction system after evaluating the results of the landfill gas collection and recovery system for a period of one year.

Public Works would like to bring to the Grand Jury's attention that results of groundwater monitoring conducting over the past several years shows that no volatile organic compound has been detected above the California Maximum Contaminant Level for Drinking Water prior to leaving County property.

Public Works would like to clarify a statement in this Grand Jury recommendation. The well described in Recommendation 1 will help the Regional Water Quality Control Board rather then Health Care Services Department track movement of landfill impacted groundwater. The Regional Water Quality Control Board regulates water quality issues.

FINDING 3: Grading is done which would not be in conformity with the Grading Ordinance if done on private property. Blowing dust would be reduced by changing grading methods to conform to the county ordinance.

PUBLIC WORKS RESPONSE: Public Works agrees but believes it to be impractical.

RECOMMENDATION 3: Use grading procedures that would be in compliance with Section 14-23 of the County's Grading Ordinance.

PUBLIC WORKS RESPONSE: The recommendation will not be implemented based upon the review of Grading Ordinance Number 3937 and discussions with the County Grading official. Public Works has determined that the use of grading procedures conforming to the Grading Ordinance are not applicable to grading at the landfill. The County Grading Ordinance is applicable to grading projects that have a beginning and an end (e.g., a development project). Public Works has been performing grading of the same areas at the landfill for 30 years, and will continue to perform grading of many of the same areas for the next 30 or more years. Grading at the landfill is similar to a grading at a mine or quarry rather then the types of grading activities covered by the Grading Ordinance. However, Public Works has enacted a number of measures to reduce blowing dust at the landfill. These include: 1) reducing the size of the borrow area to reduce the amount of area exposed to wind, 2) covering previously graded areas with wood chips to reduce the exposure of graded areas to wind, 3) shortening equipment haul roads to reduce their travel on dirt road thereby reducing blowing dust, and 4) improving the after hours dust control program. Public Works is also investigating other operational changes at the site that would further reduce the blowing dust problem and is investigating options for additional water supplies for dust control. The additional water options are discussed in finding 4.

FINDING 4: Blowing dust is a problem. The shortage of water is a serious problem. There is not enough water to spray as needed. Water that is retained in the collection trench and reclaimed is the primary source of water used to spray for dust control. Smaller areas of the surface are being exposed as one method to control dust.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 4a: Find additional sources of water.

PUBLIC WORKS RESPONSE: The recommendation has been implemented. Public Works is currently working on a number of steps to secure additional water for dust control. The primary source for water at the landfill is from an on-site water well. The collection trench supplies a limited volume, approximately 20%, of the total water currently used for dust control. Public Works is currently negotiating with the adjacent property owner to purchase water from their on-site well. This source would increase the available water by approximately 100% from current levels. In addition, Public Works has retained a geologic consulting firm to evaluate and develop additional potential on-site sources of water.

RECOMMENDATION 4b: Use alternate methods to cover the trash (mulch, foam, sheets of plastic that could be anchored down).

PUBLIC WORKS RESPONSE: The recommendation has been implemented. Public Works implemented this recommendation several years ago. Public Works has been one of the leaders in the state in using alternative daily covers. Public Works use of geo-textile blankets and the use of foam at Foxen Canyon and the Tajiguas Landfills are some of the earliest uses of these alternative daily covers in the State. Foam, geo-textile blankets and wood chips are being used at the Tajiguas Landfill to cover the trash. The use of alternate methods to cover the trash reduces the need for soil and also reduces the dust control problem.

FINDING 5: Erosion is not controlled on slopes that are being actively used.
Present use of grading to remove gullies does not correct the problem. Exposed areas are constantly being graded instead of using erosion control practices. Cost is a factor in use of control methods.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 5a: Use alternate technology such as those recommended by the County Grading Division, e.g. geo-textile or jute type netting, or other methods that would be required of private enterprise, and are more effective than merely grading.

PUBLIC WORKS RESPONSE: The recommendation will not be implemented. The on-going grading that is necessary to provide the daily soil needs does not lend itself to the use of geo-textiles or jute netting for erosion control. Although implementation of such alternatives is possible, it is not cost effective due to the on-going operations cited in the response to Recommendation No. 3. The Public Works Department does practice sedimentation control which is the goal of all parties concerned. Rather than controlling the sediment transport on the slopes at great cost, Public Works uses sedimentation basins to control sediment transport off-site. Two sedimentation basins are located adjacent to the major soil borrow area. Soil that is carried by storm water settles out in the basins prior to discharge from the site.

RECOMMENDATION 5b: A silt and sedimentation pond is needed down gradient to trap silt before it reaches the ocean.

PUBLIC WORKS RESPONSE: The recommendation will be implemented. The development of an additional silt and sedimentation pond requires the acquisition of several permits from Federal and State agencies as well review under the California Environmental Quality Act guidelines. Public Works will begin preparing an Environmental Impact Report for the expansion of the Tajiguas landfill within the next three months. This report will provide the necessary environmental review and provide necessary information to acquire the needed permits. After receipt of appropriate permits and completion of the environmental review process, Public Works will begin construction of the silt and sedimentation pond within four months.

FINDING 6: A gas collection system, in addition to the monitoring probes, is required by the federal EPA and state Air Resources Board. The system must be operating by December of 1998.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION: Install a gas collection system within the required time frame.

PUBLIC WORKS RESPONSE: The recommendation has been implemented. Public Works is aware of the Federal EPA and State Air Resources Board requirement to install a gas collection system. Public Works has contracted with an engineering firm to prepare plans for the gas collection system for submittal to the Santa Barbara County Air Pollution Control District in June 1997. The submission of the design report by June 1997 is in accordance with dates specified in the federal, state and local (proposed) requirements. Public Works is budgeting in its 1997/98 and 1998/99 budgets for the installation and operation of a gas collection system.

FINDING 7: Litter escapes from the landfill, carried by wind, or by water in the creek.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 7a: Utilize additional portable fences, built high enough to trap litter on site.

PUBLIC WORKS RESPONSE: The recommendation has been implemented. In January 1997 Public Works prepared and submitted a plan to Environmental Health Services for the control of litter that escapes from the landfill. The plan includes the construction of additional portable and permanent litter control fences, the hiring of a litter control crew, and the installation of additional trees to contain litter on-site. Most of these measures have been already implemented. Public Works will continue to evaluate litter control, and make improvements to the litter control program.

RECOMMENDATION 7b: Install screens at mouth of landfill to trap litter before it enters creek.

PUBLIC WORKS RESPONSE: The recommendation has been implemented. Public Works has installed a series of litter fences in the drainage course to prevent litter from flowing off-site. In addition, Public Works has installed litter control fences around the entrance to each drainage inlet structure. These actions are in addition to Public Works actions cited in the response to Recommendation 7b.

FINDING 8: No personnel are available after hours or on weekends to respond to complaints.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 8: Devise a system to have personnel on call to handle complaints.

PUBLIC WORKS RESPONSE: The recommendation has been implemented. Public Works has provided local community members with the home phone numbers of the operation manager and site supervisor. Following notification by the community members, the operations manger or site supervisor will dispatch personnel to the site to respond to complaints. In addition, Public Works has contracted with a private weather forecasting service to advise Public Works on the probability of either high winds or rain. Such forecasts provide operational personnel at the landfill with information on conditions that may require additional staffing and/or control measures.

FINDING 9: The Solid Waste Division Enterprise Fund has financial resources.

PUBLIC WORKS RESPONSE: Public Works agrees with the finding.

RECOMMENDATION 9: Plan, budget and implement needed improvements at the landfill.

PUBLIC WORKS RESPONSE: Public Works has implemented this recommendation. Public Works has budgeted within its fiscal 1996/97 budget and future budgets for needed improvements related to this Grand Jury Report.


Sincerely,


Phillip M. Demery
Public Works Director
County of Santa Barbara