SR 10-26-2021 4A
City Council Report
City Council Meeting: October 26, 2021
Agenda Item: 4.A
1 of 16
To: Mayor and City Council
From: Rick Valte, Acting Public Works Director, Public Works, Office of
Sustainability & the Environment
Subject: Study Session on the City's Gas Monitoring System for the Former Landfill
Site
Recommended Action
Staff recommends that the City Council conduct a study session to review and comment
on the current condition of the existing non-active landfill and its gas control and
treatment system.
4.A
Packet Pg. 512
2 of 16
Executive Summary
The City of Santa Monica operated a landfill from 1948 to 1970. The facility was closed
and capped with three to five feet of cover soil in 1970. In order to comply with new
regulatory requirements for landfills, a Landfill Gas Control and Treatment System (LFG
Control System) was installed in 1998 to monitor and control methane and other landfill
gases. This report provides a summary of the inactive landfill site located beneath
Gandara Park and portions of the Municipal City Yards located at 2500 Michigan
Avenue and a description of the LFG Control System, the regulatory requirements, and
recent monitoring results. The LFG Control System has been in continuous operation
since 1998 to monitor methane levels and to maintain safe environmental conditions for
nearby residents, park users, and City staff who work at the Yards. Oversight of the
LFG Control System is performed by a licensed independent contractor, Montrose
Environmental, that maintains, operates, and manages the LFG Control System in strict
accordance with permits from the County of Los Angeles Department of Public Health
(LADPH) and the South Coast Air Quality Management District (SCAQMD). The permits
require routine monitoring and maintenance of a perimeter probe network, LFG
extraction wells, and the LFG Control System. Additionally, the air above the landfill
surface and the interiors of the City Buildings are monitored for LFG. Compliance
reports are submitted to the LADPH and SCAQMD on a quarterly basis.
Over the past 20 years, the LFG monitoring results indicate predominantly safe
methane levels in all of the system’s 37 subsurface LFG detection probes, including a
network of monitoring probes that specifically monitor methane levels adjacent to the
Mountain View Mobile Home Park. In several instances, anomalies have been recorded
at a handful of locations that exhibit temporary increases in methane levels that exceed
the regulatory threshold of 5% by volume. These anomalies can generally be remedied
by adjustments to the LFG mechanical network, or through expansion of the control
system. A planned expansion is currently underway to address a recent anomaly
associated with utility work and construction activities at the City Yards.
Background
4.A
Packet Pg. 513
3 of 16
Landfill Background
In 1904, the Simons Brick Company established a factory to manufacture pottery, brick,
tile and clay shingles alongside the Southern-Pacific tracks and adjacent to the Sunset
Brick and Tile Manufacturing Company. The operations included a large clay mining pit
located at present day Gandara Park and portions of the City Yards. This local resource
provided materials for the construction of many buildings in the Bergamot area and
West Los Angeles.
Following the closure of the clay mine in the 1940’s, the site transitioned to a landfill that
was primarily used for the disposal of construction debris composed of wood, cement,
metal, gypsum, and other construction related materials. Based on the historic aerial
photos it appears that municipal solid waste (residential trash) was disposed at this
location from approximately 1949 to 1952. The western portion of the pit remained
unfilled until approximately 1964, at which time it also appears to have been
predominantly filled with construction debris. At the time of the landfill’s closure in 1970,
it is estimated that it contained approximately 300,000 cubic yards of refuse. It is
estimated that the pit was a maximum of 30 to 35 feet deep at its southern edge and
considerably shallower along the northern edge (about 3 to 5 feet deep.) A layer of
approximately 3 to 5 feet of soil was reportedly used as a landfill cover material at the
site.
Figure 1: Approximate Boundary of the Landfill from 1977
Discussion
4.A
Packet Pg. 514
4 of 16
The City has been actively monitoring methane levels at the former landfill site since
1996. California Title 27 regulations for control of LFG adopted in 1997 required a LFG
Control System to be installed to control gases generated by the decomposition of the
landfill material. An interim LFG Control System was installed in 1998. Construction of
the permanent LFG Control System that incorporated the interim system was completed
in the fourth quarter of 2000. The primary LFG components are methane and carbon
dioxide. Methane gases are the primary subject of this report, as methane is flammable
and thus presents safety considerations.
The objectives of the LFG Control System are:
• Reducing methane concentrations within the landfill;
• Reducing methane concentrations in native soils surrounding the landfill;
• Reducing methane concentrations in identified utility trenches; and
• Maintaining methane concentrations in perimeter subsurface detection probes
outside the landfill below the regulatory action level of five percent methane by
volume or 50,000 parts per million.
Five percent represents the lower flammability limit (LFL) for methane, which is the
lowest concentration of gas capable of producing a spark or flash of fire in the presence
of an ignition source. With methane concentration levels below the LFL, the gas would
be too lean to burn.
LFG Control System – How it Works
The system includes the following major components:
• Monitoring Probe Network: consisting of 37 subsurface probes for monitoring
LFG.
• Extraction Well Network: consisting of ten vertical wells that extract LFG from the
landfill.
• Conveyance Piping: consisting of underground piping to collect and transport
LFG from the extraction wells to the treatment compound.
4.A
Packet Pg. 515
5 of 16
• Treatment Equipment: consisting of multiple systems that treat the collected LFG
before it is discharged to the atmosphere through a 26-foot-high stack.
Regulatory Compliance – Why We Have the Landfill Gas Control and Treatment
System
Policy decisions made 80 years ago provided for a landfill to be located in the present-
day Pico Neighborhood. Operations at the landfill ceased in 1970 and, in 1996, the City
was compelled to begin monitoring the site due to changes in the California Code of
Regulations. In order to control exposure to potential LFG emissions, the LFG Control
System was installed in 1998 and expanded in 2000. The LFG Control System was
approved and permitted by the SCAQMD and LACDPH. These permits require the
following monitoring and maintenance activities:
• Bi-weekly Activities:
o Check the treatment vessels outlet for volatile organic compounds (VOCs)
and schedule a media replacement if VOCs exceeds 20 parts per million
(ppm).
o Check the blower and equipment for any LFG leaks and to ensure it is
operating properly.
o Check the condensate tank for remaining capacity to ensure it will be
pumped out and hauled away.
• Quarterly Activities:
o Monitor the vacuum methane, oxygen, carbon dioxide, and hydrogen
sulfide in all 10 LFG extraction wells and make adjustments, if necessary.
o Monitor the methane and pressure in all 37 probes (many of which have
multiple depths).
o Collect a composite sample of air from within three inches of the ground
throughout Gandara Park and have it analyzed by a certified laboratory for
methane and VOCs to ensure the total methane emissions in the park do
not exceed 25 ppm.
o Conduct instantaneous surface monitoring (ISM) for methane within three
4.A
Packet Pg. 516
6 of 16
inches of the ground surface throughout Gandara Park.
o Conduct ISM indoors throughout the City Yards buildings to check for LFG
in the buildings.
o Report findings to SCAQMD and LACDPH.
• Annual Activities:
o Collect LFG system outlet and inlet samples and have a certified
laboratory analyze them for hydrogen sulfide, methane, and VOCs to
check the functioning of the treatment system and ensure it is working
properly.
o Collect a perimeter probe sample for VOC analysis at a certified
laboratory.
4.A
Packet Pg. 517
7 of 16
The continuous monitoring of the former landfill site has produced a record going back
nearly 25 years. As a whole, this record demonstrates that methane levels – both
underground and in the ambient air environment – are generally below the regulatory
compliance threshold of 5%, with a few isolated exceptions that are described in this
report in more detail. Overall, the site generates a low volume of methane. This can be
attributed to the landfill being over 50 years old and to the composition of the waste
landfilled, which was predominantly construction debris such as concrete blocks, bricks,
and wood. Based on the volume and type of waste in place and the known time the
landfill was in operation, landfill modelling indicates that the landfill’s ability to generate
methane is very low and will continue to decrease over time.
Community Concerns About Methane and Environmental Justice
Over the years, concerns have been expressed by the community over the presence of
LFG and its potential impact on the human environment. As part of the former landfill
sits beneath a public park, concerns have been raised about the effects of emissions on
families and children and the potential for the vented methane to combust. Similar
concerns have been expressed by the neighboring residential community living adjacent
to the former landfill site at Mountain View Mobile Home Park.
The City closely monitors the LFG to track methane levels to a high degree of accuracy,
provide a historical record, and ensure a stable and safe human environment. The LFG
system’s network of monitoring probes and gas extraction wells help to form a barrier
against any potential methane leaks, and effectively monitor and extract landfill gasses
near sensitive residential areas including the Mountain View Mobile Home Park, as well
as Gandara Park. The compliance reporting requirements that are satisfied by a
licensed contractor, Montrose Environmental, ensure independent professionals
continually evaluate the system for changing conditions. The current scope of services
with Montrose Environmental covers preventive maintenance, proactive upgrades, and
field monitoring of the landfill gas extraction system to ensure optimum operation and
performance of the components in extracting landfill gases. This allows the City to go
above and beyond the regulatory requirements set by the LADPH and SCAQMD.
4.A
Packet Pg. 518
8 of 16
Members of the public may request copies of the City’s Quarterly LFG Operations,
Maintenance, and Monitoring Reports from CalRecycle (Attachment A) or from
SCAQMD (Attachment B).
Subsurface Methane Levels
Since the LFG control system began operation, required monitoring of subsurface vapor
probes has documented that methane concentrations in native soils surrounding the
landfill are generally below regulatory action levels. Similarly, the network of trench
probes that exists at the site have not contained methane in excess of the regulatory
action limit, with the exception of trench probe TP-2 located in the City Yards that is
described below. Multi-depth vertical monitoring probes are installed along the
perimeter of the landfill. A total of 37 probe clusters are used to detect any landfill gas
that may be traveling through the subsurface soil. The probe clusters each contain
shallow, intermediate, and deep probe depths.
Monitoring at Mountain View Mobile Home Park
LFG monitoring equipment installed between the landfill and the Mountain View Mobile
Home Park consists of eight perimeter probe clusters, eight landfill gas extraction wells,
and two sumps. These are located along the northeast perimeter of the mobile home
park to detect and prevent LFG migration. There were also ten former monitoring
probes situated within the Mountain View Mobile Home Park. After LFG was
consistently not detected (0.0 ppm) for an extended number of years, the regulatory
agencies no longer required the City to test and sample monitoring wells MVP1 through
MVP10.
4.A
Packet Pg. 519
9 of 16
Figure 2: Map of Shallow Probes In Compliance with LADPH and SCAQMD Requirements
Ambient Air Methane Levels
The SCAQMD permits require a composite air sample be collected quarterly within
three inches of Gandara Park for methane and VOC analysis. The results of these
samples in recent years have been consistently below the SCAQMD limit of 25 ppm.
Compliance with Regulatory Requirements
Quarterly compliance reports detailing methane levels throughout the monitoring and
control system are submitted to SCAQMD and there have been no non-compliance
violations recorded against the City of Santa Monica. Quarterly compliance reports are
also submitted to the LADPH. An inspector from the LADPH has inspected the site
4.A
Packet Pg. 520
10 of 16
quarterly for the past 20 years. During that time there have been no enforcement
actions for the Santa Monica Landfill. There have been “Areas of Concern” or minor
“Violations” noted on the inspection reports, most of which occurred back in the late
1990s and early 2000s when the LFG Control System was being installed and later
expanded. The most recent of these occurred in 2018 and 2019. They were due to
water ponding in the City Yards and exceedances of 5% methane detected in the
nearby subsurface probe PP-6. This exceedance was noted on June 13, 2019, when
5.1% methane was detected in probe PP-6B. Subsequent inspections of PP-6
consistently indicate no exceedances of 5% methane.
Anomalies in Historically Low Methane Levels
Methane concentrations exceeding 5% have occurred sporadically in certain Rule
1150.1 compliance probes. These elevated concentrations have been controlled
through LFG extraction well adjustments and upgrades on aging LFG equipment.
Upgrades have included installing new well heads and sump pumps, improving
compressor operation, and keeping the vacuum system continually running with a new
variable frequency drive which allows the City to control the vacuum system and blower.
Two anomalies identified in the continuous system monitoring warrant further discussion
in this report, as they demonstrate the City’s commitment to transparency and to
maintaining tight oversight of LFG emissions.
• Trench Probe #2– Potential Sewer Utility Off-Gassing
Only the methane concentrations in trench probe TP-2, which is located on the
north side of the City Yards in front of the Water Resources Division’s facilities,
have consistently exceeded the Rule 1150.1 limits. The methane readings
collected from this compliance monitoring probe have been higher than most of
the landfill gas extraction wells, ranging from 22.3% to 38.4% by volume in air
since 2016. Montrose believes the gas detected in probe TP-2 may not be
originating from the landfill, but instead is the product of a nearby sewer utility.
4.A
Packet Pg. 521
11 of 16
Montrose conducted gas sample fingerprinting during the first quarter of 2020 by
comparing laboratory analysis of vapor samples collected from probe TP-2 and
the closest LFG extraction well (LFG-7). The analytical results indicate the gases
are different and that TP-2 may not be detecting LFG but may be detecting sewer
gas from a nearby sewer line in the trench. LADPH is aware of the history of this
probe and there have been no violations issued for trench probe TP-2, which is
located in the City Yards area.
• Perimeter Probe Anomalies
There have been sporadic exceedance of the 5% methane detected in the
subsurface perimeter monitoring probes over the past 10 years. When elevated
levels of methane are detecting in perimeter probes, corrective actions are
performed. This usually includes checking and adjusting the nearby LFG
extraction wells.
Some of the perimeter probes are located very close to the edge of the landfill
waste and also to the LFG extraction wells. This close proximity to LFG sources,
makes it more likely to periodically have readings that exceed 5% methane. In
order to monitor the probe, it has to be evacuated by connecting it to a pump. By
putting the probe under vacuum to collect a sample, LFG from the surrounding
soil may be drawn towards and into the probe. Therefore, one-time anomalous
elevated methane readings in the perimeter probes may be due to sampling
errors and are not necessarily an indication that LFG is migrating beyond the
site’s border.
The following maps show all the perimeter monitoring probes at the site. Next to
each probe is either a green dot or yellow dot. The green dots indicate that probe
has not exceeded 5% in the past five years of quarterly readings (20 monitoring
events). The yellow dot indicates that the probe has had one or more
exceedances of 5%. Since each probe has 3 depths, the shallow, intermediate,
and deep probes are shown on three separate maps.
4.A
Packet Pg. 522
12 of 16
Figure 3: Shallow Probe Map (Green Dots = No Readings Over 5% and Yellow Dots = 1 or More
Readings Over 5% in Past 5 Years)
Figure 4: Intermediate Probe Map (Green Dots = No Readings Over 5% and Yellow Dots = 1 or More
Readings Over 5% in Past 5 Years)
4.A
Packet Pg. 523
13 of 16
Figure 5: Deep Probe Map (Green Dots = No Readings Over 5% and Yellow Dots = 1 or More Readings
Over 5% in Past 5 Years)
• Recent Anomalies at City Yards Construction Site – Expansion of the LFG
System
As a result of recent utility work and construction activities of the new Fleet
Maintenance building located at the City Yards, several new anomalies were
recently identified. The City was contacted by Southern California Gas Company
in June 2021 regarding the results of their aerial methane mapping survey, which
identified two locations with detectable levels of methane in the City Yards.
Asphalt and concrete were removed at these two locations during construction,
and planters and electrical conduit boxes were installed.
Based on a thorough investigation involving surface monitoring at multiple areas
in the City Yards, it was determined that two subsurface electrical conduit boxes
had elevated methane readings. To reduce the methane detected in these
locations, Montrose increased the vacuum at the nearest two LFG extraction
wells and the City contractor capped open conduits within the boxes. This
reduced the methane concentrations in the utility boxes. These locations have
4.A
Packet Pg. 524
14 of 16
been added to the routine monitoring program and will continue to be inspected.
In addition, Public Works is installing an additional vertical LFG extraction well to
reduce and capture methane near the surface in these areas. This work is
covered by existing contracts. Staff is preparing to submit applications and obtain
permits from the LACDPH and SCAQMD for the installation of the new well and
all necessary trenching and piping connections to the existing LFG header. A
Work Plan and Health and Safety Plan will be prepared to describe the proposed
construction activities and safety protocols to be performed at the site.
Figure 6: Proposed Location of Additional LFG Extraction Well and Piping
System Maintenance
The LFG system has performed well over the past twenty-four years, owing to a routine
maintenance schedule that continuously evaluates the condition of all mechanical
equipment. Repairs are performed when necessary, or when the opportunity to improve
4.A
Packet Pg. 525
15 of 16
the system with upgraded components is presented through advances in technology or
science. Routine maintenance and repairs are covered in the City’s existing contract
with Montrose.
Conclusion
The City maintains an inactive landfill site located beneath Gandara Park and portions
of the Municipal City Yards in the Pico Neighborhood with a Landfill Gas Control
System. The LFG Control System has been in continuous operation since 1998 to
monitor methane levels and to maintain safe environmental conditions for nearby Pico
Neighborhood residents, park users, and City staff who work at the Yards. Oversight of
the LFG Control System is performed by a licensed independent contractor, Montrose
Environmental, that maintains, operates, and manages the LFG Control System in strict
accordance with permits from the County of Los Angeles Department of Public Health
(LADPH) and the South Coast Air Quality Management District (SCAQMD).
Montrose performs biweekly system inspections to confirm the LFG Control System is
running properly and provide maintenance to the mechanical equipment. Montrose also
monitors the landfill surface and the LFG detection and collection system quarterly. By
regularly monitoring the 37 perimeter and trench probe clusters for LFG detection in the
subsurface soil, staff can identify elevated methane and perform adjustments or repairs
on the LFG extraction wells. The LFG extraction wells are monitored to ensure they are
providing the maximum LFG control at the site. The entire landfill surface is monitored
for LFG emissions and repairs and updates are made as necessary to ensure the health
and safety of the public and City workers.
Financial Impacts and Budget Action
There is no immediate financial impact or budget action necessary as a result of this
action. Staff is using existing funds for installation of an additional vertical LFG
extraction well. City Council approved funds to award a contract with Montrose
Environmental for services related to the operation, maintenance, and compliance
sampling and reporting for the City’s Landfill Gas Control System at the July 27, 2021
4.A
Packet Pg. 526
16 of 16
meeting. The total contract amount was $715,211 of which $137,990 was approved for
FY 2021-22.
Prepared By: James Velez-Conway, Senior Sustainability Analyst
Approved
Forwarded to Council
Attachments:
A. Weblink to CalRecycle Records Request Information
B. Weblink to SCAQMD Records Request Information
C. CalRecycle Records Request Information (PDF version of Attachment A
Weblink)
D. SCAQMD Records Request Information (PDF version of Attachment B Weblink)
E. Written Comments
4.A
Packet Pg. 527
4.A.cPacket Pg. 528Attachment: CalRecycle Records Request Information (PDF version of Attachment A Weblink) (4576 :
4.A.cPacket Pg. 529Attachment: CalRecycle Records Request Information (PDF version of Attachment A Weblink) (4576 :
4.A.cPacket Pg. 530Attachment: CalRecycle Records Request Information (PDF version of Attachment A Weblink) (4576 :
4.A.dPacket Pg. 531Attachment: SCAQMD Records Request Information (PDF version of Attachment B Weblink) (4576 :
4.A.dPacket Pg. 532Attachment: SCAQMD Records Request Information (PDF version of Attachment B Weblink) (4576 :
4.A.dPacket Pg. 533Attachment: SCAQMD Records Request Information (PDF version of Attachment B Weblink) (4576 :
1
Vernice Hankins
From:PNA90404 <pna90404@gmail.com>
Sent:Tuesday, October 26, 2021 10:56 AM
To:councilmtgitems; Clerk Mailbox; Clerk Mailbox
Subject:Agenda 4A 10/26/2021
Attachments:Exhibit H1.png; Exhibit J.png; ExhibitA.png; ExhibitA.png; ExhibitB .png; ExhibitC.png; ExhibitE.png;
ExhibitD.jpg; ExhibitF.png; ExhibitH.png; ExhibitH1.png; ExhibitE1.jpg; ExhibitE2.jpg; ExhibitG.png
EXTERNAL
Dear City Clerk, Please accept this email for tonight's City council meeting 10/26/2021.
Dear Mayor and Pro Tem and Council and City Manager and Staff.
Please accept this email on behalf of the Pico Neighborhood Association Agenda Item 4A.
Cris McLeod PNA Chair and Santa Monica Resident.
The Pico neighborhood has suffered for generations at the hands of City Hall, with the 10 highway and its
pollution, the City municipal yards, Multiple landfills, the trash transfer station that handles trash from all Cities
including Santa Monica, and the train maintenance yards with its noise and congested intersections and to top
it all off the Cities next big project dumping Toxic Forever Chemicals from the Hyperion water reclamation
plant in Los Angeles into the Pico Aquifers. Dumping PFAS’s into the Pico aquifers -PFAS (Polfluoroalky are
Carcinogens such as fire retardants etc) PFAS deform babies and cause Kidney cancer and more. (PFAS are
found in all reclaimed water)
Institutional racism sometimes called systemic racism is a form of racism that is imbedded as normal
practice within society or an organization such as City Hall, it can lead to discrimination in criminal justice,
employment , housing, political power and education among other issues. The cramming in of low income
housing into the Pico Neighborhood which increases the Poverty level in the Pico neighborhood is a result of
institutional racism and it is not ok to continue this behavior on the minorities that live In the Pico
neighborhood.
That’s City Halls track record so far and the future?
So, how did Santa Monica get a Landfill gas extraction treatment system in Gandara Park in the Pico
neighborhood? In 1996 The City Attorney's office began harassing the Hispanic owner of Mountain View
Mobile Home Park (see exhibit A) and MHP residents that it was their job to remediate the explosive landfill
gases floating around the MHP, and install a gas extraction system and its costs. This interfered with the MHP
resident’s purchase of the MHP, after multiple lawsuits and settlements the City stole the sale of the Park from
the residents (see exhibit B) after the multiple lawsuits the landfill gas system was a requirement to keep the
100 elderly MHP residents safe from migrating landfill gases. See case #: BC 172044 Ring vs City,
case SC58190 MVMIRA vs City, case SC59079 Abuse of Process Borean vs City:
The city owned and operated an illegal, unregistered, unpermitted Landfill for 20 plus years (see exhibit C),
also do not forget the illegal incinerator. (See exhibit D)
Item 4.A 10/26/21
1 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 534 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
2
The landfill gas extraction system only extracts VOC (Volatile organic compounds) compounds from 200 cubic
feet of the 12 acre landfill, the city yard's is 14 acres in size and sits on 7 acres of the landfill. Any readings
obtained from the gas extraction system cannot represent any noticeable amount of Methane. The landfill has
no vapor barrier installed so 99% of all landfill gases (there are many different toxic gases present) free to
escape into the local community (except during the wet season when the rain makes the ground swell
effectively closing the surface of the landfill, trapping the VOC’s underground ) releasing the 2nd most
poisonous greenhouse gas into the community 24/7 365 days a year (Methane gas is the second most
harmful greenhouse gas 20 times more poisonous than carbon dioxide),as the staff report shows new sources
of Methane gas migrate to the surface of the landfill and escape into the local environment in uncontrolled
releases “2 subsurface electrical conduit boxes had elevated methane readings and the capping of open
conduits fixes this leak ?etc” that’s incorrect, all conduits on or entering or leaving the landfill should have
grommets seals installed because of the hases to prevent landfill gases migrating from the landfill via the
conduit this is very dangerous and should not exist, this staff report has many errors or lack of information or
misinformation it should be seriously fact checked.
In 2010 MVMHP residents forced the housing dept to install 5 new landfill test probes to replace the probes
destroyed by the Cities construction project to improve the park, to date the city has not tested the new
probes, staff have said they did not install new probes.(see exhibit F showing the installation) the health &
safety of 82 families do not matter to City hall. City staff has impunity from their actions and no accountability
for misconduct, Eric Uller is the perfect example of the deep seated staff misconduct that comes from a Racist
City hall, Eric was only a systems analyst for the Information Services Department, his actions caused the
largest City cash payout which is likely the largest child molestation settlement against a city employee in U.S.
history- you recently got rid of the Housing Manager Barbara Collins who was an overt psychopath who
willfully lied with impunity and the backing of City Hall.
.
PP perimeter probe 6 2018 reading shows 20% methane gas a very high reading, the staff report says PP 6
has not read methane higher than 5 % methane for 5 years 2018 is 3 years, also you should know that 3%
methane gas is combustible inside of structures, that would include utility boxes, public restrooms, buildings
and sheds etc, 5% methane is combustible outside in the free air –methane is not just combustible it is very
poisonous to all living things, mold, insects, birds, all wildlife and humans as well. The staff report is full of
inaccuracies too numerous to fact check (see exhibit G)
All gas readings are migrated/migrating landfill gases, residents at MVMHP have suffered from paralyzing
strokes and heart attacks and mysterious malaise especially along the boundary of Gandara park (the City
leases this land to 14 homes in the MHP which is on top of the landfill) and the City yards, if the city had ever
cared about the public health and safety they would have installed a vapor barrier over the entire landfill to
control the movements of the landfill VOC gases. Even at today’s prices the landfill could have a vapor barrier,
a vapor barrier for 12 acres in size is $100K-150,000 dollars (vapor barriers are cheap and sturdy).
What should the City do with the Landfill? The Methane readings are still high in 2021 very similar to the first
readings from 1998 (see exhibits H/H1 ) the pumping system crashes many times (see exhibits J/J1 ) The city
should install a more reliable system that controls how the VOC gases leave exit the landfill, atm gases have
complete freedom to leave the landfill and roam around the Pico community at will. Halt all industrial activities
within 400 feet of the MHP property line, all trash services should be contracted out and the trash truck fleet
sold and the increased revenue that contracting out trash services and sale of the fleet $200 million dollars
that would generate annually could be used for the City to excavate the landfill and install the 2 million gallon
Item 4.A 10/26/21
2 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 535 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
3
underground water reclamation tanks in its place, install air scrubbers and wind screens at the rear of
Gandara Park to help stop airborne particulate matter PM10 & PM2.5 blowing into the park and residential
neighborhood and install a plaque in Gandara park notifying the general public there is a landfill beneath the
Park and Methane gas is present and is a danger to their health, resume monitoring the LF gas probes in the
MHP, but as usual the City will do whatever they want until another lawsuit stops them.
Thank you.
Item 4.A 10/26/21
3 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 536 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
4 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 537 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
5 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 538 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
6 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 539 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
7 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 540 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
8 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 541 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
9 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 542 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
10 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 543 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
11 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 544 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
12 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 545 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A
10/26/21
13 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 546 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
14 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 547 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
Item 4.A 10/26/21
15 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 548 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
1
Vernice Hankins
From:Maria Loya <mloyadlt@gmail.com>
Sent:Tuesday, October 26, 2021 3:14 PM
To:Council Mailbox; Santa Monica City Manager's Office; Clerk Mailbox; councilmtgitems
Cc:PNA SM; Brian O'Neil; B. Onofre; Gina DeBaca; Mary Cornejo; Marco Marin; Andrew Kalinowski; Jeff
Blake
Subject:City Council Item 3a. Study Session on Gandara Park Landfill Extraction System
EXTERNAL
Dear City Council Members and City Manager,
I'm writing you as a PNA Boardmember and mother of two boys regarding the study session on the
Gandara Park landfill extraction system. I support the letter written by Chairperson Chris McLeod
from the PNA. I would like to add to the letter sent by Mr. McLeod. Thank you for your time and
consideration.
Gandara Park Landfill
Gandara Park is a popular among young families. The PNA in the past has requested a public
hearing on the landfill gas extraction system to determine if the air quality around the park is safe and
if the gas extraction system is running well. For the first time since the landfill gas extraction system
has been put into place, the Santa Monica City Council has finally going to study the issue. The study
session is under item 3a.
Background
In the 1930s, the site of today’s Gandara Park was a clay company that had excavated a large pit to
make bricks. After the company ceased operations, the City later converted the pit into a landfill with
construction waste. The landfill was covered up and then transformed to include a park as well as
approximately half of the Santa Monica City Yards. Landfill gas contains many different gases.
Methane and carbon dioxide make up 90 to 98% of landfill gas. The remaining 2 to 10% includes
nitrogen, oxygen, ammonia, sulfides, hydrogen and various other gases. Landfill gases are produced
when bacteria break down organic waste. The former landfill at Gandara Park collected commercial
waste which has a direct impact on the kinds of gases are emitted.
The Pico neighborhood has had to endure decades of environmental dumping and concentration of
undesirable development and zoning created the concentration of toxic and hazardous operations
that include the 10 highway and its pollution, the City municipal yards, Multiple landfills, the trash
transfer station that handled trash from all Cities including Santa Monica, and the train maintenance
yards with its noise and congested intersections and to top it all off the Cities next big project dumping
Toxic Forever Chemicals from the Hyperion water reclamation plant in Los Angeles into the Pico
Aquifers.
Landfill Gas Extraction Treatment System
So, how did Santa Monica get a Landfill gas extraction treatment system in Gandara Park in the Pico
neighborhood? In 1996 Mountain View Mobile Home Park residents began to complain about the
gases being emitted. In 1998, the City began operating a landfill gas mitigation system in the area to
detect and capture migrating methane gas, treat it and vent the treated air back into the
environment. Quarterly tests required by the The South Coast Air Quality Management District
(AQMD) are conducted to check for any methane seepage. Detection levels are normally reported at
Item 4.A 10/26/21
16 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 549 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))
2
below 1 percent, which falls under the AQMD-recommended lower limit of 5 percent. Methane levels
that exceed 5 percent are considered potentially hazardous.
In 2010 Mountain View Mobil Home Park residents forced the City’s Housing Dept. to install 5 new
landfill test probes to replace the probes destroyed by the Cities construction project to improve the
park, to date the city has not tested the new probes, staff have said they did not install new probes.
The reporting has not been consistent due to the constant change in management companies.
How to Make Air Quality Safer For Pico Residents and Visitors of Gandara Park
Below you will find a set of recommendations on how to make Gandara Park safer for Pico residents
and park visitors.
1. The City of Santa Monica should consider installing a vapor barrier over the entire landfill
to control the movements of the landfill Volatile Organic Compounds (VOC) gases. This will
provide additional protection for residents and park visitors in case of emission of toxic gases
in the park area. Even at today’s prices the landfill could have a vapor barrier, a vapor barrier
for 12 acres in size is $100K-150,000 dollars (vapor barriers are cheap and sturdy).
2. The Methane readings are still high in 2021 very similar to the first readings from 1998
(see exhibits H/H1 ) the pumping system crashes many times (see exhibits J/J1 ) The city
should install a more reliable system that controls how the VOC gases exit the landfill.
3. Halt all industrial activities within 400 feet of the MHP property line, all trash services
should be contracted out and the trash truck fleet sold.
4. Excavate the landfill and install the 2 million gallon underground water reclamation tanks
in its place, install air scrubbers and wind screens at the rear of Gandara Park to help stop
airborne particulate matter PM10 & PM2.5 blowing into the park and residential neighborhood.
5. Install a plaque in Gandara park notifying the general public there is a landfill beneath the
Park and let people know where they can find the most recent reading from the Landfill Gas
Extraction Treatment System
Item 4.A 10/26/21
17 of 17 Item 4.A 10/26/21
4.A.e
Packet Pg. 550 Attachment: Written Comments [Revision 1] (4576 : Landfill Gas Monitoring system (60 mins))