Following development and approval of:
- A Final Closure/Post-closure Maintenance Plan (FCPCMP); and
- Submittal of a more rigorous “Joint Technical Document (JTD) due to complicated groundwater and geologic conditions at the Landfill,
- The North Coast Regional Water Quality Control Board deemed the JTD complete on November 5, 2011. This approval gave HWMA the approval to proceed with closure during the Summer of 2012.
- On March 8, 2012 the HWMA Board approved a two-step phased approach to enable placement of the debris from the adjacent burn ash debris site within the lined portion of the Landfill. Phase 1 (21.5 acres) was completed in the Summer of 2012, with the Authority expecting the approval of the NCRWQCB’s Waste Discharge Requirements in November of 2012. Phase 2 (10.5 acres) was initially scheduled for the Summer of 2013.
- The NCRWQCB informally requested additional modifications to the JTD to include the two-step closure process and provide additional background information to support NCRWQCB preparation of updated Waste Discharge Requirements (WDR) for the landfill. The JTD revisions were provided to the NCRWQCB in October of 2012.
- On April 27, 2013, the NCRWQCB’s Executive Director issued a Clean Up and Abatement Order naming both HWMA and Recology-Humboldt as responsible parties for the Cummings Road Burn Ash Site, along with a 18-month compliance schedule. The burn ash debris of concern was located adjacent to, but not within, the permitted landfill footprint.
Previously, the Humboldt County Local Enforcement Agency determined in October 1999 that the site posed no regulatory concern, and no follow up investigation or further action was required. During the Winter of 2005/06, heavy precipitation resulted in a landslide release of material and exposed the burn ash debris. The site was then re-examined by the NCRWQCB, and Recology and HWMA both undertook individual site characterizations of materials on their respective properties. Preliminary estimates indicated approximately 60,000 cubic yards of burn ash debris covered an area of 6.2 acres, and straddled two parcels. Neither Recology nor HWMA were responsible for any open-air burning activities or practices; as property owners, however, both parties were responsible for addressing the site conditions.