California Department of Resources Recycling and Recovery (CalRecycle) 

Closed, Illegal and Abandoned (CIA) Disposal Sites

Phase III: Remedial Work Scoping

Phase III Remedial Work Scoping is similar to the Comprehensive Environmental Response, Compensation, and Liability Act's (CERCLA) Feasibility Study (typically performed as part of a Phase II Site Characterization), in that given data from a Field Investigation will be utilized to determine the remedial recommendation for the CIA disposal site. The purpose of Phase III Remedial Work Scoping is to bring a CIA disposal site into compliance with state minimum standards via clean closure or alternatives to clean closure. A work plan and scope and estimate of repair costs for closure improvements are developed and would address remedial recommendations such as clean closure, reconfiguration and slope stabilization, capping, grading, drainage and erosion control, gas monitoring and control, security and site access measures.

Work Plan Development

A work plan includes pertinent site information and instructions in sufficient detail that contractors will be able to prepare accurate bids for site cleanup, and the successful bidder has sufficient guidance to clean up the site without delays, cost increases, or other problems. Site information should include a brief description of the site; including area, terrain, access, types and estimated quantities of wastes. Instructions should detail how the cleanup is to be accomplished; including equipment and facilities to be on the site during remediation, health and safety considerations, recycling and other disposal requirements, construction and environmental controls (site access, weight and vehicle restrictions, dust and water abatement, etc.), identification of hazardous wastes and method for handling these wastes (if any), and final site disposition.

A work plan or scope of work is required as part of the application for local enforcement agency grants, matching grants to local governments and loans to local governments. Preparation of the work plan may involve technical abilities beyond those available by the applicant. Local governmental agencies such as public works, planning department, recycling agencies, environmental review and assessment, or others may be able to provide assistance. Consulting engineers may also be able to provide assistance with preparation of a work plan.

Work Plan Template

The following document can be used as a template or guide in preparing a work plan:

Landfill Gas Monitoring and Control System Plan Review Template

This document can be used as a template or guide when preparing a gas monitoring system plan review:

Sample Work Plans

Examples of completed work plans:

Scope and Estimate Repair Cost of Closure Improvements

Cost estimates are primarily utilized to determine if it is economically feasible to remediate a contaminated site. This is only an estimate of the cleanup cost necessary to bring the site into compliance with State Minimum Standards. This cost estimate will later be refined by the contractor or agency that performs the actual remediation project.

Example

Clean Closure of Solid Waste Disposal Sites

Clean closure is defined as the complete removal of all waste and waste residuals, including contaminated soils. A clean closure is generally defined as being when waste materials and residuals are removed to a point where remaining contaminant concentrations are at or below background levels or levels established by the relevant regulatory agencies (LEA Advisory 16).

Advantages of Clean Closure

  • Increased postclosure land uses for the site.
  • Elimination of Board/LEA inspections of the site.
  • Increased postclosure land uses for the site.

Candidates for Clean Closure

  • Sites closed prior to current regulations and are facing a change in the land use which may threaten the integrity of the closed site or pose a threat to public health and safety or the environment.
  • Closed sites which have developed environmental problems, i.e., cover, gas, drainage, erosion, etc.
  • The cost of clean closure is less than or equal to postclosure maintenance and long term monitoring.

Elements of Clean Closure

  1. Site Characterization
  2. Clean Closure Plan Preparation
  3. Review and Approval
  4. Actual Clean closure
  5. Verification and Approval of Clean Closure

Elements of Clean Closure Plan

  1. Site Characterization
  2. Excavation and Material Management
  3. Confirmation of Waste Removal
  4. Post Closure Maintenance and Land Use

Examples of Clean Closure Cost Estimates

Elements of Site Characterization

  • Extent of Waste [Footprint (Length * Width) * Depth = Volume of Waste (yds3)]
  • Characterization of Waste Present
  • Levels of Contamination

For more information on clean closure read LEA Advisory #16, September 26, 1994.

Alternatives to Clean Closure/Scope Remedial Measures to Meet State Minimum Standards

Title 27, Chapter 3, Subchapter 4, Article 3, Section 20750 of the California Code of Regulations states:

"The operator shall implement a preventative maintenance program to monitor and promptly repair or correct deteriorated or defective conditions with respect to requirements of the California Integrated Waste Management Board standards, and conditions established by the enforcement agency. All other aspects of the disposal site shall be kept in a state of reasonable repair."

Minimum standards have be established for the following:

  1. Cover Maintenance
  2. Landfill Gas Monitoring and Control
  3. Drainage and Erosion Control
  4. Site Security

Also see: LEA Advisory #17: Nuisance Dumping, "What is the Appropriate Action for Illegal Solid Waste Disposal Sites?"

California Landfill Cover Law

Section 20950(a)(2)(A)(1), Title 27 CCR (SWRCB)
"For landfills the goal of closure, including but not limited to the installation of a final cover, is to minimize the infiltration of water in to the waste, thereby minimizing the production of leachate and gas."

Section 2240(A), Title 27 CCR (CalRecycle)
"The final cover shall function with minimum maintenance and provide waste containment to protect public health and safety by controlling, at a minimum, vectors, fire, odor, litter and landfill gas migration. The final cover shall also be compatible with post closure land use."

Section 21140(C), Title 27 CCR (CalRecycle)
"The EA may require additional thickness, quality, and type of final cover depending on, but not limited to the following: (1) a need to control gas emissions and fires; (2) the future reuse of the site; and (3) provide access to all areas of the site as need for inspection of monitoring and control facilities."

Section 21090(a), title 27 CCR (SWRCB)
"The RWQCB can allow any alternative final cover design that it finds will continue to isolate the waste in the Unit from precipitation and irrigation waters as well as would a final cover built in accordance with applicable prescriptive standards."

Section 20950(a)(2)(A)(1), Title 27 CCR (SWRCB)
"For landfills the goal of closure, including but not limited to the installation of a final cover, is to minimize the infiltration of water into the waste, thereby minimizing the production of leachate and gas."

Section 21140(b), Title 27 CCR (CalRecycle)
"Alternative final cover designs shall meet the requirements of part (a) [i.e., control vectors, fire, order, litter and landfill gas migration] and shall be approved by the enforcement agency."

Landfill Gas Monitoring and Control

Title 27, Chapter 3, Subchapter 4, Article 6, Section 20919 of the California Code of Regulations states:

"Where the enforcement agency, the local fire control authority, or the CIWMB has cause to believe a hazard or nuisance may be created by landfill decomposition gases, they shall notify the owner. Thereafter, the site owner shall cause the site to be monitored for the presence and movement of gases, and shall take necessary action to control such gases."

In addition, "The monitoring program shall not be discontinued until authorized to do so in writing by the appropriate agency. Results of the monitoring shall be submitted to the appropriate agencies. If monitoring indicated methane gas movement away from the site, the owner shall, within a period of time specified by the requiring agency, construct a gas control system approved by that agency."

Furthermore, Title 27, Chapter 3, Subchapter 5, Article 2, Section 21160 states:

(a) The operator shall implement and maintain landfill gas control and prevent leachate contact with the public or animals according to the requirements of this section.

(b) Gas monitoring and control shall be conducted during the closure and post closure maintenance period pursuant to Article 6, Subchapter 4, Chapter 3, Title 27 California Code of Regulations.

Drainage and Erosion Control

Title 27, Chapter 3, Subchapter 5, Article 2, Section 21150 of the California Code of Regulations states:

(a) "The drainage and erosion control system shall be designed and maintained to ensure integrity of post closure land uses, roads, and structures; to prevent public contact with waste and leachate; to ensure integrity of gas monitoring and control systems; prevent safety hazards; and prevent exposure of waste."

(c) In addition, "Slopes not underlain by waste shall be stabilized to prevent soil erosion."

Also see: Title 27, Chapter 3, Subchapter 4, Article 4, Section 20820 of the California Code of Regulations.

Site Security

Title 27, Chapter 3, Subchapter 4, Article 1, Section 20530 of the California Code of Regulations states:

"The site shall be designed to discourage unauthorized access by persons and vehicles by using a perimeter barrier or topographic constraints. Areas within the site where open storage or ponding of hazardous materials occur shall be separately fenced or otherwise secured as determined by the Enforcement Agency (EA). The EA may also require that other areas of the site be fenced to create an appropriate level of security."

Last updated: January 10, 2000
Closed, Illegal, and Abandoned (CIA) Disposal Sites, http://www.calrecycle.ca.gov/SWFacilities/CIA/
Glenn Young: Glenn.Young@calrecycle.ca.gov (916) 341-6696