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City of Carnation


City Manager's Report to Community 11.28.16

What is that "DUMP CLSR" fee on my utility bill?

(Note: The paper files on the City’s Landfill are not complete. This timeline is as close as we could get to the major issues concerning the landfill. I apologize in advance for any mistakes, inaccuracies and/or faulty information.)


From time to time someone will come into City Hall with their utility bill in hand, point to a line on the bill and ask, “What the heck is the ‘DUMP CLSR’ fee?” That fee is collected from Carnation residents and goes into the “LANDFILL POST CLOSURE FINANCIAL ASSURANCE ACCOUNT”. The City uses the revenue from that account to monitor the groundwater in the vicinity of Carnation’s old city dump that is south of town. City staff and I submitted the following report to the City Council. We have condensed the original report and edited out a list of the numerous reports and studies that Carnation has had to produce (and pay for) over the closure and post closure of the city dump.

Like many small towns the City of Carnation operated a garbage dump from the late 1930’s until 1989 when the landfill operations were discontinued as a part of a landfill closure plan. And just like many other cities the prevailing practice when the landfill was in operation was to burn the garbage and then bury it. At the time there was no consideration of the environmental consequences for this activity.

Ecological thought and waste management practices evolved over the years that the city operated the dump. Trash disposal has evolved into today’s recycle and reuse. The goal of recycling is to remove those items that can be reused, or taken out of the waste stream: chemicals, paint, electronics, metals, plastics etc. Today, the remaining waste is collected and hauled to dump sites that have been engineered to ensure that the waste is captured with no residual run-off or negative effect to the environment.

Over the years we all learned that simply burying trash or the burned remains did not solve the problem, it only moved it. Consequently, we now know that burying this mix of burned trash, paper, paint cans, insecticide, metals of all sorts, produces a toxic plume of chemical compounds that once in the ground threatens the quality of the water at various levels in the water table.

As a consequence, Carnation is required to monitor the groundwater under the old city dump. The City uses the funds received from the “Dump Closure Fee” to fund the cost of the monitoring. In order to comply with the Landfill Post-Closure Plan the City has paid to install twelve monitoring wells and nine methane gas monitoring wells. In addition, groundwater samples are taken quarterly from the wells and the samples are analyzed for numerous chemical compounds and metal.

The following information is a timeline of Carnation’s landfill/city dump:


1986: Carnation was notified by the Seattle-King County Department of Health that the City had to close the landfill. Seattle-King County Health gave a mandatory closing date that was to be no later than November 27, 1989.

1989: King County again informed Carnation that the City was out of compliance with WAC 173-304 Minimum Functional Standards, and must take steps to close the landfill. The County documented eighteen incidents of contaminated leachate problems as found by King County Department of Public Health over a period of time. (Leachate is any groundwater that flows over, under, around or through the landfill debris that could contain contaminants.) Carnation closed the dump in November, 1989.

1990: A Final Engineering Report for the Closure Plan (Alpha Engineers, Inc.)  was produced. The plan ($43,400 funded by a 50% DOE grant, with the City paying the other 50%) evaluated closure procedures and presented recommendations for the closure of the Carnation landfill. The report included plans for re-grading the site, and directing rainwater runoff to “grass lined drainage swales” and then to a sedimentation pond. The report describes options for the closure, including the use of a “geomembrane liner” to cover and keep any surface water infiltration from working its way through the refuse that had been buried.  

In addition, the design called for piping to collect and ventilate the methane and carbon dioxide gas that results from the continued decomposition of the buried refuse.

Monitoring wells were also specified to allow testing and sampling of the groundwater. The cost estimate for the landfill closure in 1990 was $354,456.

The closure project was funded as follows:

 DOE Grant (Local Toxics) $246,022
 King County CDBG   70,434
 Financial Assurance Fund33,000 
 Carnation 5,000 


In addition to the cost of closing the dump the City was required to create a fund that would cover the cost of future groundwater monitoring and analysis costs. This is the “Dump Closure Fee” that is still chargedon utility bills.

1990-1993: Approval of Landfill Closure Plan, survey and design

1994: Landfill capped by construction (“Envirocon”) final cost $383,739. Seattle-King County Health placed additional monitoring requirements on the City that included testing for methane/gas collection and dispersal, water quality testing wells, drainage and fencing. The landfill closure project was considered complete in 1995, entering the “post-closure” phase of groundwater and gas monitoring.

Monitoring History

1995-2000 First report of Water Quality by American Engineering Corporation (February 2, 1996)

Original goals/issues surrounding the early monitoring of the landfill:

Surface water should be prevented from coming into contact with the (buried) solid waste
Leachate production should be minimized and leachate migration controlled. Measures that inhibit the movement of water into or through the landfill should limit the amount of leachate that must be contained.
Gas management: Gases are a byproduct of solid waste decomposition. Carbon dioxide and methane are the most commonly produced gases. Gases must be captured underground and dispersed.
Environmental monitoring: Ongoing water quality monitoring and analysis will be required to ensure that local surface and ground waters are adequately protected.

In the period 2003-2004 during testing at the land fill it was discovered that “the seals on the groundwater monitoring wells had become damaged due to soil settling after the original installation of the wells.”  The damaged well casings allowed the infiltration of rainwater into the wells. This contamination of what was essentially rainwater compromised the results of most of the groundwater testing that was done between 1996 and 2003. (From the 2005 Carnation Budget Document)

2005: Carnation Groundwater and Landfill Gas Monitoring and Sampling Plan Pacific Groundwater Group (PGG) updated the Monitoring and Analysis Plan. At this time (2016) the City continues to work with PGG for our landfill analysis and monitoring.

2015: Monitoring Well 8-D  installed December 2015      

2015-2016: Continued Monitoring, Testing and Additional Wells

The Dump Closure Fee: The Landfill Post Closure Financial Assurance Account (Fund 406) was created to account for the dump closure fee revenue and post-closure maintenance costs of the Landfill. In an average year the fund accrues approximately $60,000 from the fees paid by the utility customers.  Annual costs for the consultant for testing the groundwater from the landfill have ranged from $35,000 to $50,000 in 2015. The reason for the higher cost in 2015 is because the city was required to install an additional test well.

Monitoring and testing of the landfill may be discontinued after thirty years if approved by DOE and the Health Department. We are currently about twenty years into testing and monitoring so the City may be able to make a case that no further monitoring or testing will be required at the end of the thirty-year period (2025).

While we may never be rid of the obligation to test the groundwater, the number of required tests and the contaminants being tested have been reduced. Our consultants, Pacific Groundwater Group (PGG) tests:

  • Each quarter. For two quarters they perform the “full suite” of tests (79) at all 9 wells; and to sample for 70 constituents at two wells during the other two quarters. In addition, PGG prepares and submits an annual report to Carnation that is shared with Seattle-King County Department of Health and with DOE. 

2016 and Beyond

The Carnation landfill has a long and difficult history. The landfill and cost of the ground water monitoring that goes with it may at times feel like an unfair burden on ratepayers. The City has tried, unsuccessfully, to convince, or prove to King County, that the County shares some responsibility for the dump closure costs since the landfill had been open to use by residents of the greater Carnation area and not just those within city limits.  We may eventually convince the regulatory agencies that the landfill requires a lower level of testing and monitoring, leading to reduced costs in the future and a reduction in the landfill closure fee. But until then the City will have to continue to charge the Dump Closure fee.

Phil Messina, Carnation City Manager