California Department of Resources Recycling and Recovery (CalRecycle) 

Enforcement Advisory Council Meeting: March 8, 2005

Response to Resolution 2005-03

June 28, 2005

Mr. Bill Prinz
Chair, EAC
Solid Waste Local Enforcement Agency
Development Services Department
1010 Second Ave Ste 600 MS 606L
San Diego, CA 92101-4998

Subject: EAC’s Recommendations for Landfill Gas Monitoring and Control at Active and Closed Disposal Sites

Dear Mr. Prinz:

This letter is in response to Enforcement Advisory Council (EAC) Resolution 2005-03, dated June 6, 2005 which was passed at the March 8, 2005 EAC meeting.

The resolution requests that the California Integrated Waste Management Board (CIWMB), in partnership with the EAC, review and draft regulatory changes to place additional and more consistent requirements for gas monitoring at active and closed disposal sites in Title 27 of the California Code of Regulations (CCR). This recommendation is consistent with the proposed changes to existing regulations in the GeoSyntec report “Landfill Compliance Study Phase II”, which was discussed by the Board in June 2004.

As a basis for this resolution, the EAC cites its understanding of the findings developed by the technical advisory group formed to review:

  • the permitting of sites with long-term landfill gas violations, and
  • existing landfill gas regulations to determine adequacy and the need for permit revisions.

The technical advisory group, led by John Bell, reviewed, analyzed and successfully incorporated needed standards and guidance into the proposed regulations for long-term landfill gas violations at permitted facilities. These draft regulations were approved for adoption at the June 14, 2005 CIWMB Board meeting. EAC’s role, through the participation of the Orange County LEA on the technical advisory group, has been instrumental in developing regulations that better protect public health and safety and the environment. The regulatory process would not be as successful without EAC’s and the Orange County LEA’s technical expertise and continued participation.

CIWMB staff will now begin the review of the landfill gas standards for active and closed disposal sites. The EAC has mentioned a specific concern regarding the potential threat of landfill gas from closed sites where there is no preexisting gas control system and where development encroaches at the landfill property boundary. After meeting with stakeholders, staff may then propose appropriate regulatory changes to the existing landfill gas regulations.

I look forward to our continued accomplishments in protecting public health and safety and the environment. Should you have any questions, please contact me at (916) 341-6311.

Sincerely,

Original signed by

Howard Levenson, Ph.D.
Deputy Director
Permitting and Enforcement Division

Attachment: EAC Resolution 2005-03

cc: Enforcement Advisory Council Members
      Ken Stuart, Chair, CCDEH Solid Waste Policy Committee
      Rosario Marin, Chair, CIWMB
      Rosalie Mulé, Member, CIWMB
      Cheryl Peace, Member, CIWMB
      Carl Washington, Member, CIWMB
      Julie Nauman, Chief Deputy Director, CIWMB

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Last updated: July 5, 2005
Enforcement Advisory Council (EAC) http://www.calrecycle.ca.gov/LEA/EACouncil/
Leta Forland: Leta.Forland@calrecycle.ca.gov (916) 341-6395