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HomeMy WebLinkAboutRES 2797Amended by Re�so hition No. 2825 CITY OF RENTON, WASHINGTON RESOLUTION NO. 2797 A RESOLUTION OF THE CITY OF RENTON, WASHINGTON, ADOPTING THE LOCAL HAZARDOUS WASTE MANAGEMENT PLAN FOR SEATTLE -KING COUNTY WITH THE PLAN ADDENDUM UPON THE CONDITION THAT IT BE AMENDED AS PROVIDED HEREIN. WHEREAS, Section 220 of Chapter 70.105 of the laws of the State of Washington requires that each local government or combination of local governments prepare a local hazardous waste plan which shall be based on State guidelines; and WHEREAS, it was determined that moderate risk waste is being disposed of with solid waste, in sewers and septic systems, or on other lands, which may be improper for reasons of public health and environmental protection; and WHEREAS, the City of Renton and King County entered into an interlocal agreement whereby the parties agree that they shall cooperate in the County's development of a Comprehensive Solid Waste Management Plan including moderate risk waste; and WHEREAS, King County, in cooperation with the City of Seattle, Metro, and the Seattle/King County Department of Public Health, has completed a local Hazardous Waste Management Plan for Seattle -King County including suburban cities who signed the interlocal agreement referenced above, that is designed to meet State guidelines and to significantly reduce and divert hazardous waste from the solid and liquid waste stream, and issued on August 28, 1989 a final plan and environmental impact statement; and WHEREAS, the City, through the Suburban Cities Association, participated in the Solid Waste Interlocal Forum, which through 1 RESOLUTION NO. 2797 Resolution No. 90-001 recommended adoption of the plan, as amended in the Plan Addendum, by King County and the cities within the County; and WHEREAS, under the current plan the budget for local hazardous waste management programs will be developed by the Management Coordination Committee and recommended to the Seattle - King County Board of Health for review and approval and will be funded in part by State funding, with the remainder funded through fees levied on solid waste collection (80 percent) and sewer fees (20 percent) which will be passed on to the public; and WHEREAS, the State of Washington planning guidelines require that the plan be adopted by resolution by all participating cities; and WHEREAS, the Suburban Cities Association has raised certain questions related to budget and evaluation. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RENTON, WASHINGTON, DO RESOLVE AS FOLLOWS: SECTION I. The above recitals are found to be true and correct in all respects. SECTION II. The City of Renton hereby adopts the Local Hazardous Waste Plan for Seattle -King County, as amended by the Plan Addendum, provided, however, that the Plan is further amended to provide as follows: 1. The Management Coordination Committee shall be composed of five members, that being one representative from each of the following entities: King County, City of Seattle, Seattle/King K RESOLUTION NO. 2797 County Department of Public Health, Metro, and Suburban Cities Association. 2. The Management Coordination Committee shall unanimously approve the evaluation criteria, design, reports, and strategy as referenced in Chapter 3 of the Plan. 3. The Management Coordination Committee shall unanimously agree to each proposed annual plan and budget. PASSED BY THE CITY COUNCIL this 21st day of May , 1.990. Marily Petersen, City Clerk APPROVED BY THE MAYOR this 21st day of May , 1990. E rl C ymer, M 't'o+�r Approv s to form: Lawrence J. War n, City Attorney RES.93-5/14/90-as. 3 ,. Local Hazardous Waste Management Plan for Seattle -King County Final Plan and Environmental Impact Statement for the Management of Small Quantities of Hazardous Waste in the Seattle -King County Region August, 1989 El -1 U U 0VL1i 10 4 O 0 Mw Local Hazardous Waste Management Plan for Seattle -King County Final Plan and Environmental Impact Statement for the Management of Small Quantities of Hazardous Waste in the Seattle -King County Region August, 1989 ADDENDED ADDENDUM TO SEATTLE -RING COUNTY LOCAL HAZARDOUS WASTE PLAN In the review of the Local Hazardous Waste Plan by members of the suburban cities, King • County Council staff, and the Department of Ecology, some outstanding issues were brought up. The addendum was developed to answer these concerns. The issues included: 1) The role of elected officials 2) Independent review and oversight of the Plan .. 3) Potential for program duplication 4) Administration of the Plan by the Health Department 5) Plan implementation 6) Suburban cities representation within the organizational structure 7) Cost effectiveness of the Plan 8) Resources devoted to Household Hazardous Waste program versus the Small r Quantity Generator program 9) Methods used to calculate program costs 10) Specifics of the evaluation program .. The addendum was written so that all existing language in the Plan is indicated by italics, additions by regular type, and deletions by strikeouts. Each amendment is followed by the page number it will appear on in the final printing of the Plan. The addendum has been reviewed and accepted by all participants in the review process. The Plan was given a recommendation of approval by the Interlocal Forum on January 12, 1990, after these changes to the Plan had been made. W W M W go M L:A SOLID WASTE INTERLOCAL FORUM RESOLUTION 90-001 RECOMMENDATION TO THE ADOPTING JURISDICTIONS Regarding the LOCAL HAZARDOUS WASTE MANAGEMENT PLAN FOR SEATTLE -KING COUNTY FINAL PLAN FOR THE MANAGEMENT OF SMALL QUANTITIES OF HAZARDOUS WASTE IN THE SEATTLE -KING COUNTY REGION AUGUST, 1989 WHEREAS, a local hazardous waste plan to manage hazardous wastes generated in small quantities by households and businesses (herein referred to as moderate risk wastes) was prepared in accordance with the State Hazardous Waste Management Act (RCW 70.105.220(1)); WHEREAS, the Plan proposes a regionally coordinated approach to managing moderate risk wastes; WHEREAS, the Plan will be funded by a state tax on *the sale of hazardous substances and by fees assessed on solid waste collection, on "self haulers" using transfer stations and landfills, and on sewage treatment facilities; WHEREAS, the adoption procedure identified in the Plan includes action by the Solid Waste Interlocal Forum and the Forum was requested to review the Plan and refer the Plan to King County and the cities within the County that will be adopting and implementing the Plan; and WHEREAS, Forum members have collaborated in the development of the Plan and the Plan Addendum. NOW, THEREFORE, BE IT RESOLVED THAT, the Solid Waste Interlocal Forum recommends approval of the Plan, as amended in the Plan Addendum, and adoption and implementation of the Plan by King County and the cities within the County. Adopted January 12, 1990 Ted Hunter, Chair Solid Waste Interiocal Forum SOL l D WASTE INTERLOCAL FORUM The following members of the Solid Waste Interlocal Forum vote DO PASS on Resolution 90-001 before the Forum this 12th day of January, 1990: County Executive Tim Hill King County ouncilmember Paul Barden King County VACANT Councilmember King County Councilmember Bruce Laing' King County .L Councilmember Lois North King County EXC'-'SED Councilmember Jim White City of Kent Suburban Cities Association 7 Seattle ja--:: .�or Norm Rice Councilmember George Benson City of Seattle VACANT Councilmember City of Seattle Cou'Pe(member Jim Street City of Seattle D 2'� 7 7 Mayor Doris Cooper City of Kirkland Suburban Cities Association -71 Counc�fj � ber Ferry Lukens City oellevue Subur Cities Association .. ADDENDUM TO SEATTLE -KING COUNTY LOCAL HAZARDOUS WASTE PLAN No Amendment A - page xiii Hazardous Waste Waste that presents a danger or risk to human health or the environment, from one or more of the following characteristics: toxic, corrosive, ignitable, of reactive;, persistent or carcinogenic. By regulation, hazardous waste does not include infectious, medical or radioactive wastes. r Amendment B - page 2 of Summary r"' mannerc. When any of these hazardous substances are no longer needed, they become hazardous '� wastes. Small quantities of hazardous wastes produced by businesses and households are not directly regulated by federal or state programs. Household hazardous wastes ("HHW") are "categorically exempt", meaning they are not considered legally "hazardous" regardless of the quantity of waste. The State of Washington groups specific types of hazardous wastes into two categories; "dangerous waste" and "extremely hazardous waste". Under these classifications, businesses that generate more than 220 pounds of "dangerous waste" per month, or more than 2.2 pounds of "extremely hazardous waste" per month, are subject to regulation. A business is considered a small quantity generator ("SQG") when it produces less than 220 pounds of dangerous waste per month, (approximately half of a 55 -gallon drum) or less that 2.2 pounds of extremely hazardous waste per month. SQGs are conditionally exempt from state and federal hazardous waste regulations, as long as waste generation and storage remain below this designated threshold level. However, they are still responsible r' for managing their hazardous wastes in an environmentally sound manner. M Amendment C - page 13 of Summary Based onpublic comments and input from local governments, a combination of funding sources is recommended, ' and on lecal utilities through Board 4 Health fie -es with reliance on local solid waste haulers and sewer utilities through Board of Health fees, and state grant programs. This .. strategy assures that sufficient funding will be available. sw 1 W 1W ■rr Amendment D - page 17 of Summary - Table 3 .. FUNDING ALLOQ4TIONS OURCES .. Amendment E - page 2-14 Household hazardous wastes are those old or unwanted products that exhibit any of the .r characteristics of hazardous waste. They may be toxic, corrosive, ignitible, or reactive, persistent or carcinogenic, but are exempt from federal and state regulation because of their household origin. so Amendment F - page 2-16 M Businesses that generate hazardous wastes have been regulated through the federal Resource Conservation and Recovery Act, the federal Clean Water act and the Washington State Hazardous Waste Management Act for over a decade. However, any business that generates less than 220 pounds per month of hazardous waste or less than 2.2 pounds per month of extremely hazardous waste, is conditionally exempt from state and federal ow hazardous waste regulations. Amendment G - page 2-36 so The Health Department has broad authority to enforce existing state hazardous waste .r requirements and to adopt additional regulations pertaining to hazardous waste as it affects the public health (R.C.W. 70.95.160, County, City or Jurisdictional Board of Health Regulations). .o Amendment H - page 2-37 Thirty-nine sewerage agencies in King and Snohomish Counties contribute wastewater to Metro's large interceptor sewers which flow to Metro's five wastewater treatment plants. aw Metro is required, as a condition of its NPDES permit, to control the input of stormwater and hazardous waste into its system. Metro issues permits and authorizations for sewer system users who discharge significant quantities of wastewater and/or hazardous contaminants. As a condition of obtaining a waste discharge permit, the permit holder may be required to install pretreatment facilities, make plant or process alterations or monitor discharges (RCW 90.48, WAC 173-208 and WAC 176-216). Amendment I - page 2-54 4 23 10 so R IM The complex interwoven nature of local Me- agencies' responsibilities creates a potential for .. gaps and overlaps within the regulations governing hazardous waste management and disposal. For example, some local sewer agencies may prohibit discharge of certain materials, including hazardous materials, to the sewer system. Some solid waste landfills .. and transfer stations prohibit hazardous materials from the landfill, while some facilities make no distinction between solid and hazardous waste. Sinee the regulations Were wr-itten or --a; all. Most often, the existing rules and regulations pertain to both citizens and the business community, although many people are not aware that regulations exist to manage small quantities of hazardous materials. W Amendment J - page 3-6 details of the Plan are expected to change over time as conditions change. COST EFFECTIVENESS .. STRATEGY The approach taken in this plan has been to address all hazardous waste generated by households and SQGs, although certain waste streams are targeted for special attention. Some commentors have asked whether a plan which targets only those wastes possessing the greatest risk might not be more cost-effective. There are three significant questions that need to be addressed regarding the cost of this comprehensive moderate risk waste management Plan. in 1. Are the most dangerous wastes being diverted first from municipal disposal? 2. Are these wastes being diverted in the most cost-effective manner? 3. Is there some point at which it is unreasonably expensive to try and divert a larger percentage of moderate risk waste? That is, does the goal of maximum diversion aw become unrealistic at some point? Ideally the Plan would: a) identify each waste stream; to b) evaluate the risk posed by continuing to allow each waste stream to be indiscriminately disposed; and C) determine the cost of diverting enough of this waste stream so that the risks posed would be acceptable. .. N M .. Such an analysis would be not only time-consuming and expensive, it would also be virtually impossible to obtain results that could be meaningfully translated into program r design. This is due to the complexity of the waste stream and the complexity of the resulting risk analysis. av Household Hazardous Waste and Small Quantity Generator Waste consists of hundreds of individual chemicals (see pages 2-24 and the Guidelines for Local Moderate Risk Waste Plans). New products and new chemical formulations are being developed and brought into the market constantly, so this list expands rapidly. Chemical hazard is determined according to the following characteristics and properties; toxicity, flammability, corrosivity, reactivity, carcinogenicity, persistence and the EP toxicity test. One pesticide product, for example, may contain several chemicals, and may be both toxic and flammable. Public health risks, or occupational risks of any individual product depend on: The .o chemicals contained in that product; the hazard characteristic (s) of the chemicals; the degree of hazard accorded to each characteristic; the quantity of the chemical; the potential for exposure; and routes of exposure. Risk for a given product may be different depending .r on whether it is being assessed for a use, storage, or disposal situation. Toxicity assessments may change for a particular chemical as new data are published. Environmental risks depend on other properties of a product: Solubility and mobility - .rr chance of moving into surface or groundwater, persistence and degradability - how long it stays around in a hazardous form; toxicity to non -human and non -target species; potential no for penetrating landfill liners; and, potential for being broken down by sewage treatment processes. Again, the risk would be different depending on its use, storage, or disposal situation. .w Liability is another risk that must be taken into account when dealing with hazardous chemicals. There are significant liability risks associated with occupational exposures of garbage and sewer utility workers. In addition, future cleanups of disposal sites caused by contamination or higher standards are a major potential liability. A waste stream risk assessment would not only be very complicated to perform, it is also of unlikely to yield straightforward conclusions that would allow us to rank the hazard of each waste stream, and to establish the appropriate level of effort to put into each. r As an alternative to performing an elaborate risk assessment of each waste stream, the Plan tackles the issue according to a cost-effective management strategy. The approach chosen for this Plan was to accept the fact that each waste stream needs to be managed, and then to calculate the most efficient and cost-effective way of doing this. Waste management integrates elements of waste reduction, recycling, and disposal. Waste No reduction means not producing the waste in the first place. This can be accomplished by using alternative processes to perform tasks requiring hazardous chemicals, through product substitution -- using alternative, less hazardous chemicals to perform a task, or by ■o purchasing in smaller quantities and using up the material. It is the highest priority management strategy established by state law, because it is the most protective. Where go 0 WA to 0 feasible, it is also the cheapest strategy per unit of waste. The second priority is recycling, .. which conserves resources and keeps wastes away from final disposal endpoints. Last, and by far the most expensive, is disposal, either in a hazardous waste landfill, or a hazardous waste incinerator. The Plan accepts these priorities, and establishes waste reduction and recycling goals for each waste stream (see tables on page B-7). Each waste stream has a different potential for reduction or recycling. The goals established were based on knowledge available at the time, and best professional judgement about future trends and alternatives. r, For example, pesticides are considered to have a high potential for waste reduction, while for waste motor oil, the potential is virtually nil. Pesticides are a candidate for waste reduction because other effective alternative methods and products can take the place of hazardous materials. Education on the proper use of pesticides could decrease waste significantly. There is no alternative, at present, for motor oil, so in this case we have assumed minimal waste reduction. The opposite is true for recycling. There are no recycling processes for small quantities of discarded pesticides, but almost all motor oil is readily recycled, once it is collected. The key to accomplishing waste reduction is education. Whether for businesses or for ` households, clear, readily available, repeated information must be provided to make this strategy work. The education programs for both HHW and SQG wastes are strong parts of the overall Plan in order to provide this focus. SQGs in particular have a strong incentive to pursue waste reduction, as this saves them the costs of waste disposal. Industries and business organizations are already researching and testing alternative processes and products, and the Plan's SQG Education and Technical Assistance programs are designed to coordinate with and provide incentives to these private sector efforts. Education efforts are also important to the success of recycling. People must learn not to pour waste oil and other chemicals down the drain, but to bring them to a collection facility. The education programs also focus on getting basic information to the public and businesses on what hazardous wastes are, how they must be handled, and where and how they can handle them. Collection points are essential for both recycling and disposal programs. The goal is to r generate the least amount of waste, and to strive to reduce the amount disposed to the greatest extent possible. TARGETED WASTES Although targets have not been established for waste stream types, targets have been .. established for waste stream management methods. A line item in the budget is identified as "targeted wastes". The purpose of this money is to support demonstration projects which will look at alternative ways of managing different components of the moderate risk r.. waste stream. Currently a demonstration project is in progress which investigates the possibility of recycling used latex paint, and which will evaluate the non -recyclable latex to determine whether it can be disposed as a non -hazardous waste. This evaluation involves 5 M ■. sampling, and discussion with regulatory agencies regarding designation of the waste. Latex paint was chosen because it is the highest volume material brought to collection wo facilities as household hazardous waste, and because it seemed likely that much of it could be handled more cost-effectively than as a hazardous waste. A used oil program, to evaluate methods of collecting used oil in greater quantities, is also planned. Future candidates for pilot projects are solvent -based paints and solvents. The goal is to find out if there are more efficient, and higher priority ways of handling certain waste streams. These programs are shown as pilot or demonstration projects because it is through a small scale effort that the cost-effectiveness of these alternative approaches can be determined. Not all of them will prove to be worth while on a large scale. One example is the analysis on battery recycling done by King County Solid Waste. It proved not to be cost effective to collect all household batteries for recycling. The wastes chosen first are the ones that occur in the greatest quantities, and which have am the most promise for better management. The purpose of these efforts is finding strategies which are the least costly, both in terms of present dollars, and in terms of future risks and liabilities, and to manage wastes as much as possible at the higher priorities -- waste ar reduction and recycling. On the SQG side, the programs target specific industries rather than specific wastes. The r Audits/Surveys and SQG Education and Technical Assistance programs, for example, are starting with the types of businesses that occur in largest numbers, and that produce problematic wastes. Currently these are auto and marine repair and maintenance businesses, and printing/graphics businesses. CUSTOMER SERVICE A second reason for an across-the-board program is customer service, and positive public response. A high priority in the development of the Plan was to design programs that met the needs of the public. The local experience, the experience of other governments, and "" public opinion surveys have all confirmed that the public needs a simple message and a convenient program. For instance, when a Roundup in Tacoma advertised that they would not accept latex paint, it was still the highest volume item received. The message that "' certain materials will be collected, but not others confuses and alienates people. The more specific the level of discrimination (for instance, these pesticides are okay to put in the trash, but not those), the less positively the program is viewed. or Most SQGs generate multiple types of wastes. It would be inefficient to perform site visits designed to provide general education about hazardous materials and proper management, "® and then indicate that programs for only two of their wastes were available. It would also send a message that proper handling in general is not a high priority. Selective management compromises the credibility of the program and will cloud enforcement .o activities for problem situations. r1 W r IS THERE A POINT OF DIMINISHING RETURNS? We are only beginning to address the management of moderate risk waste. The first objective of the Plan is to establish a basic program that will address the needs of all the ., citizens of King County. Starting at such a low level, the value of each increment of funding is high. At first, the demand for collection will increase as the public becomes more educated, and as stored materials are brought in. After a period of time, there will be a leveling out as waste reduction begins to impact the situation, and as accumulated wastes are collected. As more programs are added, and more wastes diverted, the incremental value of programs may flatten and we will need to more carefully evaluate the benefit of additional programs. This will be an important role of the evaluation component. Amendment K - page 3-18, 19 The Health Department will also conduct an SOG Passive Materials Exchange to facilitate the transfer of wastes unwanted hazardous materials from the generator to a party that can use them. The Health Department has already begun a materials exchange called, 'IMEX", or the 'Industrial Materials Exchange". One and a half FTEs currently work in the program. Under this program, the Health Department is in contact with businesses with information concerning usable wages materials. A description of the waste materials listed with IMEX is entered on a computer and made available through a bi-monthly catalog. Amendment L - page 3-26 aw The primary purpose of the evaluation component is to measure progress in achieving the goal and objectives of the Plan listed on pages 1-4 and 1-6. Regular evaluation during the course of Plan implementation will allow participating agencies: r. 7 W 9W kill aw The primary purpose of the evaluation component is to measure progress in achieving the goal and objectives of the Plan listed on pages 1-4 and 1-6. Regular evaluation during the course of Plan implementation will allow participating agencies: r. 7 W 9W * to compare projections in the Plan with actual results; s * to determine the effectiveness of different types of programs; * to compare program elements to determine their relative efficiency; * to determine program costs per unit of waste diverted. go The Plan is an overall game plan for a twenty year moderate risk waste management program. It is expected that the programs will evolve over the years in response to new 40 information, and as the impacts of implementation have their effect. The evaluation component of the Plan is intended to be used to identify refinements and modifications into the program components. Such changes will be incorporated into the process of designing wo the annual budget and program which will be presented to the Seattle and King County Boards of Health for approval. Successful evaluation depends on appropriate measurements, data collection, and record .r keeping. Some of this work is already being done. Seattle Solid Waste performs waste stream sampling of the solid waste from their transfer stations. Hazardous wastes are identified in this sampling. King County Solid Waste Division's proposed 1990 budget includes a waste stream clearance program, in addition to a waste stream monitoring program that will start in late 1989. Seattle maintains records at their permanent household .v hazardous waste collection shed about quantities and types of wastes collected, numbers of customers, where customers come from, and costs of facility operation. King County will also keep comprehensive records from their mobile collection facilities. .r Public opinion surveys performed for the Plan (see Appendix D) and at Roundups have measured public awareness and needs regarding Household Hazardous Wastes. The Health Department and Metro have performed surveys of Small Quantity Generators in the South Park and north Kent areas to determine the most common types of businesses, and the types of wastes they produce. The recent "Waste Information Network" trade fair for small business generators also surveyed businesses for types of waste streams, and usefulness of existing educational and technical assistance programs. A study comparing costs of a permanent collection facility versus the costs of a Roundup no was prepared by Seattle's Office for Long-range Planning, and they have received grant money to perform a study comparing a variety of Household Hazardous Waste Collection options in the state, and especially in King County. Some preliminary work is also "" planned for next year on developing part of an evaluation system. A consultant will analyze evaluation techniques for measuring public attitudes and practices over time, and develop a sampling technique for measuring the change over time of hazardous waste aw disposed in the garbage. These techniques will be implemented to establish a baseline of existing conditions. Evaluation criteria and methodologies will need to be developed for each type of program component: HHW Education, HHW Collection, SQG Education, SQG Collection, Compliance, and plan management structure. The Plan proposes that this preliminary work be performed as the first year implementation task of the evaluation component. The .e aw evaluation criteria will include both activity indicators and effectiveness indicators such as .. the following: Activity Indicators: no * numbers of businesses served; * level of participation at collection facilities; quantities and distribution of educational materials; * publicity; M M .. MW M WM up M up 0 F -J OW Effectiveness Indicators: * changes in the quantity of hazardous wastes in municipal waste streams; * quantities and types of wastes collected; * costs per unit of waste collected under different collection programs; aw * changes in public attitudes and practices; * changes in business waste management policies and practices; * customer satisfaction. No The Plan proposes that the methodology for evaluation and the analysis itself be carried out by consultants at the direction of the Management Coordination Committee. Technical go committee staff will be responsible for day to day management of the consultant services contracts. This work will be proposed and performed as a part of the annual overall program and budget approved by the Boards of Health. Actual data collection and record .r keeping for specific program components will be performed by the implementing agency. Detailed on-going evaluation is an integral part of the plan implementation. Because many as of these programs are new, an on-going evaluation is a necessary part of putting together annual work programs. In addition, a separate, more inclusive evaluation which focuses on the overall effectiveness of the program will be conducted by an organization not .r associated with program implementation, such as the University of Washington. This organization will do periodic program evaluations or audits, similar to what the General Accounting Office would do for federal programs or an Office for Management and Budget aw might do at the local level. They would evaluate the organizational structure as well as program effectiveness. The evaluation component of the Plan will be coordinated by three 1/3 FTEs in Health, Metro, and Seattle's Office for Long-range Planning. They will be responsible for ensuring that the evaluation component is implemented, and that all implementing agencies are collecting data in a consistent fashion. Amendment M - page 3-26 Costs of the evaluation component range from $140,000 in 1990 to $125,000 in 1994. PLAN PROGRAM COSTS All of the cost figures are based on the projected solid waste stream tonnages through the year 2009. These were obtained from the Comprehensive Solid Waste Plan developed by 4W King County Solid Waste Division. An assumption that one percent of the solid waste stream was considered hazardous was then made. This figure represented a median percentage derived from available information on waste composition studies, done both locally and nationally. It was also assumed that 10 go ■d Im M fifteen percent of the hazardous waste produced was disposed of in the liquid waste stream �. the remaining eighty-five percent entered the solid waste stream. Studies from other areas of the country indicated that about thirty-three percent of the waste is generated from household activities, and the remaining sixty-seven percent from commercial and industrial �• sources (budget assumptions begin on page B-8, and total Plan budgets are on pages B- 16 - B-27). r. The process was then expanded with the development of diversion goals. These goals reflected the levels of reduction, recycling and disposal that the technical committee felt were achievable [Table B-4]. These diversion goals were done on an item by item basis, and were based on current and projected waste handling practices and product availability. The issue of targeting of wastes was addressed at this point. When the diversion goals were developed, differing levels of reduction, recycling, and disposal were considered, in effect targeting specific wastes using the criteria of risk, economic feasibility, and availability of alternative technologies and products. Using this information, estimated tonnages of hazardous waste that would need to be reduced, recycled or disposed of were developed.- Information obtained from surveys and collection events were incorporated into these projections. Programs were then developed around these projections. Budgets for the various program elements were developed on the basis of the diversion goals. These were based on the number of staff and associated costs that were felt would be needed to implement the programs [See Technical Appendix B-8, Budget Assumptions]. Salaries for these positions were based on a level of $45,000 for program coordinators, $40,000 for field personnel, $32,000440,000 for education staff and $34,000 for collection staff members. The costs included benefits. Administrative and supply costs were set at 25%-30% depending on the program. One new car at $20,000 was assumed for each two field personnel, with operating costs of $1,500 per person. These elements were brought ` together in plan components, and these in turn into the Final Plan. Costs for the disposal options were obtained from the costs of operating Roundups and current disposal costs available through local Treatment, Storage and Disposal Facilities (TSDs). These costs are weighted costs, in that they are a composite of all the costs associated with differing disposal options ranging from recycling to incineration to landfilling. The costs for HHW are $1,300 per ton (actual cost figures from both Roundups and the South Transfer Station collection facility operation), and costs for SQG wastes are $682 per ton. The costs differ between the two waste types because the composition of their respective waste streams differ. The Plan budget appears to show that the same level of resources are being put into Household Hazardous Waste programs and the Small Quantity Generator hazardous waste programs, despite the fact that SQG wastes constitute 2/3 of the total moderate risk waste stream [Table 3-2]. This is because the Plan proposes that SQGs pay their own disposal costs. 10 11 M M Disposal is the most expensive component of the program, per unit of waste. Plan projections estimate that in 1991 the private sector will be responsible for disposal costs w from SQGs amounting to $236,000. This is based on the projected number of businesses who will respond to educational programs. As the programs reach further, and as more businesses start to manage their wastes properly, this amount will increase. r The question of whether commercial generators should pay for their own waste disposal, or whether the costs should be borne by the agencies was discussed during the planning as process. It was decided that SQGs would pay their own costs for the following reasons. First, it is inappropriate for public agencies to be funding private businesses. Waste management is a cost of doing business, and must be accepted as such. Second, disposal go costs are a great incentive for businesses to actively seek waste reduction strategies. This incentive would be lost if disposal was subsidized. Third, the private sector has the choice of passing on all costs of doing business to its customers. This gives additional we competitive incentive for waste reduction programs, and provides a mechanism for businesses to recover disposal costs. It is recognized that there are small businesses who have been accumulating wastes over a .. period of time, because they are uncertain about how to deal with them. It is also recognized that the start up costs of a management program can be considerable. For these reasons the Plan proposed a five year subsidy program which will be available to provide assistance to Small Quantity Generators who want to properly dispose of accumulated wastes, and set up a waste management program. .. In order for the programs of the Plan to be fairly funded, the funding mechanism has been set up so that commercial accounts pay for the SQG programs, and residential accounts • pay for HHW programs. Amendment N - 3-28 Table 3-4 "' State Funding Local Toxics Control Account King County Add-on to the State Hazardous Substances Tax Local Share Funding Amendment O - 3-29 .. In addition, Ecology is has proposed revisions to the hazardous waste fees charged generators of hazardous waste in compliance with Section 16 of Initiative 97. %W Amendment P - page 3-30 Table 3-5 FUNDING SOURCES 12 7 e u D Amendment Q - page 3-30 Table 3-5 z State funding is based on estimates. Grants have not yet been secured. Agency staff will actively pursue state funding. 0 W M U_ -j a rw UN +r r r ■. %W 13 M Amendment R - page 3-38 LJ or .. The rule and ordinance that set the fees will also create an interagency Management Coordination Committee that will oversee the development of an "annual implementation no plan" and budget for disbursement of funds. The committee membership will be composed of senior staff (similar to the Senior Managers Committee for Plan development, Appendix A) designated in the rule by position (e.g. Director, City of Seattle Solid Waste Utility) and at will include mpresenwi one representative each from the major participating government entities, namely King County, the Health Department, City of Seattle, Metro, and the Suburban Cities. to As stated earlier, the Health Department will have representation on both the management and technical committees. They will have staff involved in the implementation of program elements in HHW Education and SQG Education and Compliance. There will also be staff committed to administering the funds collected. The administration of the funds will be under the direction of an annual Plan. The Plan "r will be recommended by the Management Coordination Committee to the Boards of Health. The Boards of Health will establish fee schedules that will be collected by the Health Department to cover the costs of operating the Plan. The budgets of the agencies implementing the Plan will go through the normal annual review by their respective councils. The councils retain the ultimate authority through this budgetary process for the direction that the plan takes. The Suburban Cities will be represented on the Management Coordination Committee along with other implementing agencies (King County, City of Seattle, Metro, and the Health Department). This committee will review the annual evaluation, modify the Plan accordingly by developing the following year's recommended Plan and budget. The recommended plan and budget is then presented to the Boards of Health which either adopt them and set the corresponding fee schedule or modify the them. All departmental budgets are analyzed by County, City of Seattle and Metro Councils. These councils always retain the right to modify the proposed budgets. The Management Coordination Committee will have responsibility for Plan implementation. to If the annual plan is adopted, multi-party agreements will be drawn up by all agencies participating in plan implementation. These agreements will describe the scope of work that agencies will be committing themselves to. The interlocal agreements will be .r administered by the Health Department. This will be the responsibility of the Budget and 14 M 77 40 Contracts Coordinator. These agreements will also describe the method of reimbursement to agencies for work performed. In addition, the Plan is developed so that all interested suburban cities could and would be no actively encouraged to participate in any or all of the program elements. The level of involvement of the suburban cities is only limited by their desire to participate. W Amendment S - page 3-38 •r The Program Coordinators of the -six—seven Plan Components will work together in a staff - level committee, and will be responsible for developing the annual plan and budget. Other staff involved in Plan implementation will participate in this staff committee as necessary. .. Although these coordinators are located in specific agencies, this does not imply that only those agencies will be responsible for those programs. Their duties are to insure that the annual plan is completed with a minimum of duplication county -wide. Amendment T - page 3-41 Agencies participating in Plan development have taken responsibility for implementing and operating various programs. These assignments have been made primarily on the basis of „ legal authority, expertise and willingness. It is expected that all participating local jurisdictions will participate in program evaluation, development of annual implementation plan and other activities necessary to maintain a regionally -coordinated plan. Specific assignments may change over time, when suburban cities become actively involved or responsible for program implementation. The role of the suburban cities will be described in greater detail in Amendment V. Elements of the Plan have been performed since the early 1980's. The Health Department has operated it's Hazards Line since 1983. Roundups were initiated in 1986 and have been held every year since then. Both Metro and the Health Department have been involved in audits and surveys of businesses. These were conducted in 1986 and 1988 to determine the disposal practices of differing commercial and industrial waste streams. The City of Seattle has had their permanent collection facility for almost a year now. Metro sponsored a very successful workshop for SQGs early this year, and are planning to make this an annual event. The County's mobile collection unit started operation in September. The major agencies involved in the Plan have incorporated the programs that they are responsible for in their respective 1990 budgets. They all anticipate initiating the new programs that are scheduled to come on-line next year. M Amendment U - page 3-42 g. 15 MW Health Department. R.C.W. 70.05.060 (Powers and Duties of Local Board of Health) authorizes local health boards to enact necessary rules and regulations and to establish fee .w schedules for services for the preservation, promotion and improvement of the public health. R.C.W. 70.95.160 (County, City or Jurisdictional Board of Health Regulations) specifically identifies solid waste handling as subject to local Board of Health Regulations. ,rr The Seattle -King County Department of Public Health will collect and administer the fees, and enter into agreements with other jurisdictions for disbursement of funds. The HHW Education Coordinator, Budget and Contracts Coordinator and a part-time Evaluation Coordinator will be based at the Health Department. In addition to coordinating HHW Education programs, the Health Department will be responsible for the HHW and SQG Telephone Information Line, the SQG Passive Waste Exchange, the SQG Audit Program, and a member on the Management Coordination Committee. Amendment V - page 3-43 M Role of Suburban Cities ED The suburban cities will be participating in the implementation and operation of various we programs and facilities as they see fit. Specific areas of involvement include: Public Education All HHW Education programs that comply with the Plan criteria are 4W eligible for funding through the Plan. Suburban cities can apply for funding to develop such programs. All materials developed under the Plan will be available to other jurisdictions including the suburban cities. The suburban cities may also want to use the No HHW Schools Program curricula. HHW Mobile Collection Facilities All suburban cities will have access to the HHW Mobile Collection Facility two times a year. As stated in the Plan, a second mobile facility will come on line in 1990 and a third is scheduled for startup in 1991. As these facilities begin operation, they will be routed to the suburban cities more frequently. �+ HHW Permanent Collection Facilities One new permanent collection facility is scheduled to be developed in each year from 1990 to 1994 for a total of six permanent .o collection facilities. These facilities will be located in areas around King County with the highest population density to optimize the use of the facility [Figure 1]. These facilities 16 .r e A�I�L11�1111�111111 MII �M N Y 11 K r Role of Suburban Cities ED The suburban cities will be participating in the implementation and operation of various we programs and facilities as they see fit. Specific areas of involvement include: Public Education All HHW Education programs that comply with the Plan criteria are 4W eligible for funding through the Plan. Suburban cities can apply for funding to develop such programs. All materials developed under the Plan will be available to other jurisdictions including the suburban cities. The suburban cities may also want to use the No HHW Schools Program curricula. HHW Mobile Collection Facilities All suburban cities will have access to the HHW Mobile Collection Facility two times a year. As stated in the Plan, a second mobile facility will come on line in 1990 and a third is scheduled for startup in 1991. As these facilities begin operation, they will be routed to the suburban cities more frequently. �+ HHW Permanent Collection Facilities One new permanent collection facility is scheduled to be developed in each year from 1990 to 1994 for a total of six permanent .o collection facilities. These facilities will be located in areas around King County with the highest population density to optimize the use of the facility [Figure 1]. These facilities 16 .r e would be eligible for funding of capital and operational costs from the approved plan +' budget. Suburban cities expressing an interest in having a permanent facility in their area will have priority in the siting process. Bellevue, Kirkland other areas have already expressed an interest in permanent collection facilities. SQG Information Development and Resources All businesses in King County generating small quantities of hazardous waste will have the opportunity to obtain information and assistance from the Telephone Information Line, the SQG Resource Library and the Industrial Material Exchange (IMEX). .. SQG Technical Assistance Programs All businesses in the suburban cities will have the opportunity to call on the On -Site Consultation Services for assistance in developing practical waste management solutions. SQG Auxiliary Collection Facilities Two auxiliary collection sites are planned to serve SQGs in the areas of King County where TSD facilities and services are not readily available. These areas include northern and eastern King County. SQG Mobile Collection Facilities Two facilities are planned for operation; one in 1990 we and one in 1992. These facilities will be set up in areas around King County for a scheduled period of time, similar to the HHW mobile collection facility services. The suburban cities are the prime areas targeted for the operation of these facilities. The Response Network This interagency network of enforcement officials, agency inspectors and other field staff from all jurisdictions in King County will be trained to q. conduct comprehensive inspections of business operations. This network will function to identify all aspects of hazardous waste management problems and will refer specific problems to the appropriate agency for a follow up inspection. Suburban cities' agencies up will be active participants in this program. Interagency Regulatory Analysis Committee A committee of local and state representatives will meet on a regular basis to review and update existing regulations. �` Suburban cities will be represented in this committee. SQG Survey and Audit Program SQGs located in the suburban cities will be either no surveyed or audited through this program. The survey and audit program will serve three purposes: 1) to obtain information about waste quantities, types and management practices; 2) to disseminate information to the businesses and; 3) to institute compliance proceedings, "w when necessary. The survey and audit field staff will coordinate with existing audit and inspection programs in each locality. Evaluation Suburban cities implementing programs would be responsible for collecting data for evaluating programs. 17 M r Plan Implementation and Organization Structure Management Coordination Committee The suburban cities are a member of the on Management Coordination Committee that will oversee the development of an annual implementation plan [Figure 3-5]. The committee will recommend an annual plan and budget to the City and County Councils and the Solid Waste Interlocal Forum. 4W Staff Coordinators (Program Coordinators) The staff coordinators will work together in a staff -level committee and will be responsible for developing the annual plan and budget. Suburban cities staff involved in program implementation can also participate in this staff - level committee. Amendment W - page 3-43 State Role --and Recommendations for State Action Amendment X - page 3-44 w go .r Local Add-on Tax. Local governments should be permitted to supplement the state hazardous substances tax through a local add-on tax. Such a tax is an equitable means of funding hazardous waste programs, because it places the burden on those using hazardous products. Charging users of hazardous products for the cost of management and disposal of hazardous waste better reflects the true cost of such products. Ecology, working with local governments, should propose such legislation at the next legislative session. Block Grants. A block grant approach to disbursement of state funds is preferred, with plan implementation funds allocated to those jurisdictions with approved, adoptable plans 'o based on their percentage of the state's population. .W Amendment Y - page A-28 SQG PASSIVE E MATERIALS EXCHANGE so In a passive waste materials exchange, a broker acts as a clearinghouse for unwanted hazardous products, matching up businesses that have such products with those that can use them. The broker never takes possession of the wastes materials, but acts as a referral service through a phone line or a newsletter. ENVIRONMENTAL AND HEALTH ASSESSMENT Participants in the was materials exchange run some risk of injury from exposure to hazardous materials. des Materials would be transported either by the donor or the recipient; risks to health and the environment are similar in this instance to SQGs transporting wastes to collection sites or TSDs. at ad 4d r COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS The feasibility study would determine whether a waste materials exchange geared to the needs of SQGs would be compatible with existing programs and plans. LEGAL ISSUES Liabilities for both donors and recipients for wa&tes materials handled. Amendment Z - page A-33 This program would provide businesses with the opportunity to request an On -Site Consultation on hazardous waste management. Experts would walk through the business, provide information on environmental compliance and help establish best waste management practices specific to that business. This would be a consultation program only, and would not be linked to any inspectionlenforcement program. if theon 3eses an illega4 amount of steed waste- (i.e. more than 220 pounds)-, but the C ess vise qualifies as a II It ' The gr-aee peried would 1 be given one _ti�rylp�t which . proper- waste�Y1anagA'Y.oflt T squired. 0 17 Amendment AA - page B-2 LEGAL DEFINITIONS OF HOUSEHOLD AND SMALL QUANTITY GENERATOR HAZARDOUS WASTE The Department of Ecology Planning Guidelines for Local Hazardous Waste Plans (July 1987) define household hazardous waste as follows: "Household Hazardous Waste means any ... 19 s i.tac+ .4.,'er££ c k +i+A�vt4.t�4Jqu # MINION s MW ?.� ?' .,,w ' a, y tw#"` ae ,xa*� ''r"€Gy)ric-s4' �•e Sam s r Y'NE Rai i # a OLDS fie" TAN .r£ 1 M` �tY` m* .4 YY ^t k W� : art `11 � "'. `'$ > �S '",,"'vr MKc I''�`:•,' ;s a '.'-+s`-,aN11, N Q �"���� � ��� a i* � � t-4, ��° y 4.4 R Y x 0 gt .07 v � 'f i4 xa WA F 'jr N WAS"Soon W + s a 00 any - We E .. 771 FACT SHEET am Title: Final Local Hazardous Waste Management Plan Description: The King County Solid Waste Division, City of Seattle Office for Long-range .� Planning and Solid Waste Utility, Metro and Seattle -King County Health Department are proposing a plan for managing hazardous waste generated in small quantities by households and businesses in King County. Proposed facilities and programs included in the plan are: .. Permanent collection facilities for hazardous waste generated by households (HI-iW) and in small quantities by businesses (SQG). M 0 Mobile collection facilities for HHW and SQGs. • Public education programs to result in the proper disposal and ultimate reduction in the amount of household and SQG hazardous waste generated. Technical assistance for businesses that generate small quantities of hazardous waste. ,r0 Enhancement and enforcement of waste disposal regulations. Lead Agencies and Responsible Officials no King County Solid Waste Division Rodney Hansen, Manager 400 King County Administration Building 500 Fourth Avenue Seattle, WA 98104 Staff Contact: Scott Blair, 296-4434 City of Seattle Office for Long-range Planning Richard Yukubousky, Manager 200 Municipal Building 600 Fourth Avenue Seattle, WA 98104 Staff Contact: Martha Burke, 684-8056 City of Seattle Solid Waste Utility Diana Gale, Director 505 Dexter Horton Building 710 Second Avenue Seattle, WA 98104 Staff Contact: Chris Luboff, 684-7644 r W so ii Municipality of Metropolitan Seattle (Metro) Office of Water Quality John B. Lampe, Superintendent 821 Second Avenue Seattle, WA 98104 Staff Contact: Dave Galvin, 684-1216 +. Seattle -King County Public Health Department Charles Kleeberg, Chief of Environmental Health .. 201 Smith Tower 506 Second Avenue Seattle, WA 98104 Staff Contact: Todd Yerkes, 296-4783 Responsible SEPA Official so Gregory M. Bush, Manager Metro Environmental Planning Division 821 Second Avenue MS -92 Seattle, WA 98104 Staff Contact: Jane McFarland, 684-1167 Licenses and Permits Required Specific licenses and permits depend on the facilities selected for implementation. They could include: • Local land use and development permits; • EPA/State identification number for collection facilities handling regulated .o amounts of hazardous waste; • Local fire department permits; • Wastewater discharge authorization. no Authors and Principal Contributors Scott Blair, King County Solid Waste Division Martha Burke, City of Seattle Office for Long-range Planning Ray Carveth, Metro Office of Water Quality Henry Draper, King County Solid Waste Division David Galvin, Metro Office of Water Quality Jennie Goldberg, Metro Office of Water Quality Ellen Kissman, City of Seattle Office for Long-range Planning Chris Luboff, City of Seattle Solid Waste Utility Jane McFarland, Metro Environmental Planning Division Sydney Munger, Metro Office of Water Quality Division Lisa Sepanski, City of Seattle Office for Long-range Planning Wally Swofford, Seattle -King County Public Health Department Laurel Tomchik, Metro Office of Water Quality Todd Yerkes, Seattle -King County Public Health Department M No 111 r. Date of Issue: August 28, 1989 Nature and Date of Final Action: King County Council, Metro Council and the councils of the cities in King County will adopt and implement the plan to manage local hazardous waste. Adoption by the jurisdictions is expected to occur through December, 1989. The A plan will then be submitted to the State Department of Ecology for approval. Subsequent environmental review: Project -level environmental reviews will be prepared, as required, during plan implementation. Location of Background Material: Copies of all technical appendices are available for review at the lead agencies named above, and at all branches of municipal and King County libraries. The technical appendices are: .. Appendix A: Program Elements • Appendix B: Technical Information • Appendix C: Issue Paper .. Appendix D: Public Involvement Program Cost of Final Plan/EIS: No charge M an OW M .. M or TABLE OF CONTENTS v SUMMARY Page WHY IS A HAZARDOUS WASTE MANAGEMENT PLAN NEEDED? .... 1 Hazardous Chemicals Become Hazardous Wastes ............... 1 Cumulative Effects .................................. 2 Potential Problems .................................. 3 WHAT IS BEING DONE ABOUT HOUSEHOLD AND SMALL QUANTITY GENERATOR HAZARDOUS WASTES? ................ 4 A COMPREHENSIVE PLAN FOR THE FUTURE .................. 5 The Planning Process ................................ 5 Goal and Objectives ................................. 6 Plan Description .................................... 7 HHW Education ............................... 7 HHW Collection and Waste Handling ................. 9 SQG Education and Technical Assistance ............... 9 SQG Collection and Waste Handling .................. 11 Compliance ..................... I ............ 12 Evaluation ................................... 12 Waste Management Projections and Costs ................... 13 HOW CAN THE PLAN BE PAID FOR AND IMPLEMENTED? ......... 13 Financing....................... ............ .... . 13 Fee Levels and Rate Impacts ....................... 17 Plan Implementation ................................. 17 WHAT ARE THE POTENTIAL ENVIRONMENTAL IMPACTS AND HOW CAN THEY BE MITIGATED? .............................. 22 Siting.......................................... 22 Design.......................................... 22 Transport........................................ 23 Health and Safety ................................... 23 VISION OF THE FUTURE ................................. 23 SECTION 1: INTRODUCTION THEISSUE........................................... 1-1 GOAL AND OBJECTIVES ................................. 1-4 THE PLANNING PROCESS ............................... 1-6 so M r TABLE OF CONTENTS vi • Page PUBLIC PARTICIPATION ................................ 1-8 am THE PLAN .......................................... 1-10 M 11 91 1 M� SCHEDULE FOR COMPLETION ............................ 1-10 ORGANIZATION OF THE FINAL PLAN/EIS ................... 1-11 SECTION 2: BACKGROUND INFORMATION LOCATION AND SETTING ............................... 2-1 Natural Environment ................................ 2-1 Built Environment ................................. 2-3 Population .................................. 2-3 Population Density ............................. 2-3 Population Growth ............................. 2-5 Economy ................................... 2-5 Zoning for Hazardous Waste Facilities ..................... 2-8 EXISTING WASTE FACILITIES ............................ 2-8 Solid Waste Facilities ............................... 2-9 Wastewater Facilities ................................ 2-11 Municipal Sewerage Systems ...................... 2-11 Septic Tanks ................................ 2-13 Storm Drains ................................ 2-13 DESCRIPTION OF HAZARDOUS WASTE ..................... 2-13 Household Hazardous Waste ........................... 2-14 Small Quantity Generator Hazardous Waste ................. 2-16 Projections of HHW and SQG Waste 1989-2009 .............. 2-17 CURRENT DISPOSAL OF HAZARDOUS WASTE ................ 2-21 Long-term Storage ................................. 2-22 Household Hazardous Waste ...................... 2-22 Small Quantity Generators ........................ 2-26 Solid Waste Stream .................... .... ........ 2-26 Household Hazardous Waste 2-26 Small Quantity Generator Hazardous Waste ............. 2-27 Liquid Waste Stream .................... .... ........ 2-27 Household Hazardous Waste ...................... 2-28 Small Quantity Generator Hazardous Waste ............. 2-28 Septic Tanks ..................................... 2-30 Storm Drains ..................... ................ 2-31 ■r TABLE OF CONTENTS vii no Page EXISTING PROGRAMS FOR MANAGING HAZARDOUS WASTE ..... 2-31 Information and Education ............................ 2-31 Collection and Disposal .............................. 2-32 Household Hazardous Waste ...................... 2-32 Small Quantity Generator Hazardous Waste ............. 2-34 ROLES, REGULATIONS AND RESPONSIBILITIES ............... 2-35 Federal Environmental Protection Agency ................... 2-35 State of Washington Department of Ecology ................. 2-35 Seattle -King County Department of Public Health ............. 2-36 Local Solid Waste A eg ncies ........................... 2-37 The Municipality of Metropolitan Seattle (Metro) .............. 2-37 Local Sewer Utilities/Districts .......................... 2-37 Local Drainage Utilities .............................. 2-38 Local Fire and Building Departments ..................... 2-38 PROBLEMS AND NEEDS ................................ 2-38 Solid Waste Stream ................................ 2-38 Liquid Waste Stream ................................ 2-40 Worker Safety .................................... 2-44 Impacts on the Public and the Community .................. 2-45 Summary....................................... 2-46 PROGRAM NEEDS .................................... 2-47 Education Programs ................................ 2-47 Household Hazardous Waste ...................... 2-47 Small Quantity Generators .... ........ .... . . .. . ... 2-49 Collection Programs ................................ 2-50 Household Hazardous Waste .......... ........ .... 2-50 Small Quantity Generators ........................ 2-51 Regulation and Compliance ............................ 2-51 REFERENCES ........................................ 2-55 SECTION 3: PLAN DESCRIPTION PLAN DESCRIPTION ................................... 3-1 HHW Education Component ....... ........ ............ 3-6 HHW Education Program Elements .. ............ .... 3-10 HHW Collection Component ........................... 3-11 HHW Collection Program Elements .. .... ..... .... 3-12 Targeted Waste Collection/Recycling ................. 3-15 SQG Education and Technical Assistance Component ........... 3-17 ON r M UN to F11 on ON TABLE OF CONTENTS viii Page SQG Education Program Elements ................... 3-18 Technical Assistance Program Elements ............... 3-19 SQG Collection Component ........................... 3-20 SQG Collection Program Elements .................. 3-20 Compliance Component .............................. 3-21 Compliance Program Elements ..................... 3-22 Evaluation Component ............................... 3-24 .. PLAN FINANCING AND IMPLEMENTATION ................... 3-26 Financing ....................................... 3-27 State Funding ................................ 3-27 •� Local Add-on to the State Hazardous Substance Tax ....... 3-31 Local Funding ............................... 3-32 Plan Implementation ................................ 3-35 .. Summary ....................................... 3-40 Plan Adoption .................................... 3-40 Roles of Ma -or Participating Local Jurisdictions ............... 3-41 Role of Private Sector ............................... 3-43 State Role and Recommendations for State Action ............. 3-43 Funding Issues ............................... 3-44 .. Office of Waste Reduction Role .................... 3-44 Targeted Waste ............................... 3-45 Product Labeling .............................. 3-45 Amnesty Program ............................. 3-46 Compliance ................................. 3-46 go SECTION 4: AFFECTED ENVIRONMENTS, POTENTIAL IMPACTS AND MITIGATION MEASURES WATER QUALITY IMPACTS: THE PLAN AS MITIGATION ........ 4-1 COLLECTION FACILITIES: POTENTIAL IMPACTS AND PROPOSED ' MITIGATION ........................................ 4-3 Collection and Storage Structure Design .................... 4-4 Construction -Related Impacts ........................... 4-5 Drainage ....................................... 4-5 Land Use ....................................... 4-5 Environmental Health Risks ........................... 4-7 ~ Contingency Planning for Emergencies .................... 4-9 Emergency Response ................................ 4-10 Transportation .................................... 4-11 Routing of Hazardous Wastes .......................... 4-12 Traffic and Circulation at Collection Sites .................. 4-12 M TABLE OF CONTENTS ix SECTION 5: RESPONSIVENESS SUMMARY APPENDIX A: PROGRAM ELEMENTS APPENDIX B: TECHNICAL INFORMATION APPENDIX C: ISSUE PAPER (bound separately) APPENDIX D: PUBLIC INVOLVEMENT DOCUMENTS (bound separately; Solid Waste Funding Allocations and Fees 1990-1994 ............ supplement contained in this document following Appendix B) TABLES Page Table 1 Program Elements and Implementing Agencies ................. 8 Table 2 Plan Budget Summary ................................ 15 Table 3 Funding Allocations 1990-1994 .......................... 17 Table 4 Solid Waste Funding Allocations and Fees 1990-1994 ............ 18 Table 5 Sewerage Funding Allocation and Fees 1990-1994 .............. 19 Table 1-1 Examples of Hazardous Household Substances ................ 1-2 Table 1-2 Examples of Small Quantity Generator Waste Categories ........ 1-3 and Businesses Types Table 2-1 1988 Population of Incorporated Cities and Towns in King County 2-4 Table 2-2 Population Estimates and Projections for Seattle ........... .... 2-7 and King County Table 2-3 Estimated and Projected Western King County Land Use ..... .... 2-7 by Type (1970-2000) Table 2-4 Business Groups Surveyed In King, Pierce and Thurston Counties ... 2-18 Table 2-5 "High Probability" Dischargers of Contaminants by Industry Type ... 2-18 Table 2-6 Household Hazardous Waste Tonnage Projections ............. 2-20 Table 2-7 Small Quantity Generator Hazardous Waste Tonnage Projections .... 2-20 w an 10 ow OR .. Im M TABLE OF CONTENTS x FIGURES Figure 1 Permanent Collection Facility ........................... 10 Figure 2 Projections of HHW Management .... .... .... .... ....... . . 14 Page Table 2-8 SQG Hazardous Waste Generation and Disposal for King, ........ 2-24 Regulated, Conditionally Exempt and Unregulated Hazardous Pierce, and Thurston Counties Table 2-9 SQG Hazardous Waste Management Practices for South Park ...... 2-25 King County and Incorporated Cities and Towns .............. and N.W. Kent Areas Figure 2-2 Table 2-10 Residential Contribution of Commonly Detected Metal .......... 2-29 Municipal Solid Waste Facilities ........................ Toxicants to Seattle Metro's Wastewater Treatment Plants Figure 2-4 Table 3-1 Program Elements ................................. 3-3 Table 3-2 Budget Summary .................................. 3-7 Table 3-3 Waste Diversion Summary ............................ 3-9 Table 3-4 Financing and Implementation Strategies Suggested in the Draft Plan . 3-28 Table 3-5 Funding Allocations 1990-1994 ......................... 3-30 Table 3-6 Solid Waste Funding Allocation and Fees 1990-1994 ........... 3-36 Table 3-7 Sewerage Funding Allocation 1990-1994 ................... 3-37 Table 4-1 Tons of HHW and SQG Waste Projected to Enter the ........... 4-3 Environment and Municipal Waste Streams FIGURES Figure 1 Permanent Collection Facility ........................... 10 Figure 2 Projections of HHW Management .... .... .... .... ....... . . 14 Figure 3 Projections of SQG Management ................. ..... . 14 Figure 1-1 Regulated, Conditionally Exempt and Unregulated Hazardous Waste Generators .................................. 1-5 Figure 2-1 King County and Incorporated Cities and Towns .............. 2-2 Figure 2-2 Population Density and Distribution ...................... 2-6 Figure 2-3 Municipal Solid Waste Facilities ........................ 2-10 Figure 2-4 Municipal Wastewater Treatment Facilities .......... ........ 2-12 P, TABLE OF CONTENTS xi Figure 3-5 Plan Implementation Organizational Structure .... ............ 3-39 Page • Figure 2-5 Breakdown of HHW and SQG Wastes by Type ............... 2-15 Figure 2-6 Contribution of HHW and SQG Waste to Municipal Waste Streams .. 2-19 •• Figure 2-7 Hazardous Waste Tonnage Projections for 1990-2009 ........... 2-21 �r Figure 2-8 Disposal Methods for Household Cleaners .................. 2-23 Figure 2-9 Disposal Methods for Pesticides/Herbicides .................. 2-23 Figure 2-10 Disposal Methods Paints/Solvents ........................ 2-23 Figure 2-11 Disposal Methods for Automobile Products .................. 2-23 Figure 2-12 Products Listed as Hazardous by King County Residents ......... 2-48 Figure 2-13 Hazardous Products Identified in the Home .................. 2-48 Figure 2-14 Preferred Disposal Options for HHW ..................... 2-52 .r► Figure 2-15 Preferred Travel Distances for HHW Disposal ................ 2-52 Figure 2-16 Public Willingness to Pay for HHW Disposal ................ 2-53 Figure 3-1 Washington State Waste Management Priorities ............... 3-2 Figure 3-2 Projections of HHW Management ........ ............ .... 3-5 Figure 3-3 Projections of SQG Waste Management .................... 3-5 Figure 3-4 Permanent HHW Collection Facility ...................... 3-14 Figure 3-5 Plan Implementation Organizational Structure .... ............ 3-39 Hazardous Waste Local Hazardous Waste Household Hazardous Waste Small Quantity Generator DEFINITIONS Waste that presents a danger or a risk to human health or the environment from one or more of the following characteristics: toxic, corrosive, ignitable or reactive; by regulation, hazardous waste does not include infectious, medical or radioactive wastes. Small quantities of hazardous waste not regulated by federal or state laws; specifically, household hazardous waste and small quantity generator (business) hazardous waste. Waste from residential sources composed of old or unwanted products that exhibit any of the characteristics of hazardous waste. A business that generates hazardous waste in amount below regulatory thresholds, generally less than half a 55 -gallon drum per month or batch. ACRONYMS CFR Code of Federal Regulations DOT Department of Transportation (State or Federal) Ecology Washington State Department of Ecology EIS Environmental Impact Statement EPA U.S. Environmental Protection Agency FTE Full -Time Equivalent (employee or staff person) HHW Household Hazardous Waste LTCA Local Toxics Control Account PLV Passenger Licensed Vehicle RCRA Resource Conservation and Recovery Act (the federal law that regulates hazardous waste) RCW Revised Code of Washington SEPA State Environmental Policy Act SQG Small Quantity Generator (of hazardous waste) TSD Treatment, Storage and Disposal facility (licensed hazardous waste management company) WAC Washington Administrative Code •r .w Mn PR r ■r► A r J I D W re a we SUMMARY 1 This Final Plan/EIS proposes a regionally -coordinated program to address the challenge of managing hazardous wastes gener- ated in small quantities by households and businesses in King County. This plan will protect the environment by decreasing the amount of these hazardous wastes disposed of in municipal solid and liquid waste streams. Under this plan, households and businesses are encouraged to reduce the amount of hazard- ous products used and wastes generated by changing pur- chasing and use practices and by recycling or treating wastes. In 1989, county residents and businesses have disposed of 19,000 tons of these wastes in the trash, down the sewer, into storm drains, or directly onto the ground. Disposal of these wastes in this fashion can result in garbage and sewer worker exposure to hazardous substances, disruption of services, environmental contamination, and clean-up liability. King County jurisdictions are recognized as national leaders in management of small quantities of hazardous waste. In the last three years educational programs and collection events have increased citizen awareness and have created a demand for better services. Despite their popularity, past household hazardous waste collection events have collected only a tiny portion of the total waste generated. Much of what has been collected represents old materials stored for twenty years or more. In response to state regulations and public interest and concern, King County jurisdictions have cooperated to develop a region- al program to significantly reduce the amount of these hazard- ous wastes produced, to divert those wastes that are generated to appropriate collection facilities, and to recycle or treat as much as possible of the wastes collected. WHY IS A HAZARDOUS WASTE MANAGEMENT PLAN NEEDED? Hazardous Chemicals Become Hazardous Wastes Hazardous chemicals are widespread in our modern society. Many hazardous substances are constituents of consumer products used around the house, garage, garden or hobby shop, t Ignitability Corrosivity 1 S � r Reactivit7 Toxicity Cumulative Effects SUMMARY ;ed by local businesses in manufacturing or providing services. They are as common as gasoline, paints and bat- teries, printing inks, degreasers and dry cleaning solvents. Hazardous chemicals pose a risk to human health or the envi- ronment if mishandled. They include toxic pesticides, caustic drain openers, ignitable paint thinners and other reactive or explosive materials. When any of these hazardous substances are no longer needed, they become hazardous wastes. Small quantities of hazardous wastes produced by businesses and households are not directly regulated by federal or state programs, although management of most industrial and many commercial hazardous wastes (when generated in quantities greater than 220 pounds per month) is regulated. Household hazardous wastes ("HI -IW") are categorically exempt from federal and state regulations, meaning that HHW are not considered legally "hazardous" regardless of the quantity of waste. A business that produces less than 220 pounds per month (half a 55 -gallon drum) of hazardous wastes is considered a small quantity generator or "SQG." SQGs are conditionally exempt from regulations; as long as waste generation and storage remain below the 220 pound threshold, these businesses are not subject to hazardous waste regulations, however their hazardous wastes must be disposed of in an environmentally sound manner. Small quantities of hazardous waste from individual households and businesses end up in municipal waste streams -- in the trash or down the drain. Some wastes, for example, mercury, are quite toxic, while others, such as DDT, are very persistent, and even in tiny amounts can present problems in a municipal waste system. However, a more important concern may be the potential effects from many small amounts of waste from all the households and businesses in the region added together. For example, a small amount of paint thinner poured down a drain may seem insignificant, but if every household in the county discarded a cup of thinner, more than 37,000 gallons of the hazardous solvent would enter the area's waters. In 1989, the 1.4 million people and 100,000 businesses in King County will produce 1.7 million tons of solid waste and, after recycling, disposing of 1.3 million tons, as well as over 70 billion gallons of wastewater. 1 .r W 7-1 m W 10 r W ar as • SUMMARY 3 An estimated 19,000 tons of hazardous waste could be found in municipal waste streams: 16,000 tons in the solid waste .. and 3,000 tons in the sewer. In both waste streams, SQG waste accounts for about two-thirds of the tonnage, or 13,000 tons, and HHW one-third, or 6,000 tons. If a program is not implemented to address these wastes, the total tonnage of HHW and SQG wastes is projected to increase to 33,000 tons per year by 2009. M Potential Problems Solid Waste • worker injuries • equipment damage • landfill leachate contamination 7 Wastewater • worker injuries • pipe damage • sludge contamination 7 • discharge to water or air • septic tank/drain field groundwater contamination • septage contamination Other Avenues • storm drain contamination • hole -in -the -ground groundwater contamination Storage • home safety/ poisonings POTENTIAL PROBLEM AREAS w A R Both the City of Seattle and King County have adopted solid waste management plans calling for aggressive recycling and waste minimization which will result in a significant reduction in the amount of solid waste generated. Without a comple- mentary program to reduce hazardous wastes, the concentration of hazardous chemicals in solid waste will increase. HHW and SQG hazardous wastes have the potential to cause a variety of problems for human health and safety and the environment. More than 95 percent of the municipal solid waste in King County goes to the Cedar Hills Landfill. Smaller landfills operate on Vashon Island and in the rural east county. Hazardous wastes thrown in the trash endanger garbage collectors and workers at transfer stations and landfills. Hazardous chemicals in solid waste can leach out of landfills, possibly damaging landfill liners, complicating the treatment of collected leachate or passing untreated into the environment. HHW and SQG hazardous wastes can also cause problems in the liquid waste stream. Acids and caustic chemicals can damage sewer pipes and treatment plant equipment, and en- danger treatment plant workers. Also, they can pass through the treatment plant untreated, contaminating sludge or entering local waters. These chemicals can settle out in septic tanks or percolate through drain fields, contaminating groundwater. Storm drains are another pathway for hazardous wastes. Stormwater washing off parking lots, streets and yards carries pollutants into storm drains. Products dumped down catch 1 SUMMARY 4 1 basins and storm drains go directly into local bodies of water untreated. Finally, hazardous waste stored for long periods in peoples' homes increases the risk of accidental poisonings, fires or explosions. As can be seen, hazardous wastes of any kind or in any amount can cause problems when disposed of in municipal waste streams, and they do not belong in the environment. As .� the population continues to grow and environmental standards continue to get stricter, local governments must do as much as possible to reduce hazardous waste production. A program that effectively manages hazardous waste at the local level will help protect public health and the environment, as well as meet state requirements. .r WHAT IS BEING DONE ABOUT HOUSEHOLD AND SMALL QUANTITY GENERATOR HAZARDOUS WASTES? King County local governments are national leaders in this emerging environmental issue. Regional HEW collection events, called Round -Ups, have been held in 1987, 1988 and 1989. The City of Seattle operates a HHW collection facility at its South Transfer Station, open four days each week. The City of Bellevue sponsors a HHW collection site that is open two Saturdays a month. The Seattle -King County Health Department provides five collection points for pesticides and PCBs. In addition, a private company in Seattle offers a free service for HHW collection one day a week. Through these events and services over 500 tons of HHW were collected in 1988 alone. Yet, this is only a tiny fraction of the hazardous waste being generated and stored in peoples' homes. As local governments have become more aware of the need for HHW services, they have moved to do more. In 1989, an ad- ditional permanent collection site is being developed by Seattle Solid Waste Utility and Metro, and a mobile HHW collection service will be initiated by King County Solid Waste Division. Bellevue is considering the continuation of its service. Existing educational and outreach services include the Health Department's Hazards Line (296-4692), as well as the produc- tion and distribution of brochures, fliers and other printed materials by many local agencies. Up to this point, however, am W VA e M SUMMARY 5 .. resources devoted to education, especially to waste reduction, have been limited. +� Education for SQGs has included a resource guide, workshops organized through trade associations and some surveys and audits of small businesses. The Waste Information Network •� (WIN) committee, representing small businesses and local agencies, sponsored a successful hazardous waste trade fair and meets regularly to coordinate other SQG activities. Resources devoted to HHW and SQG programs by local governments (Metro, King County, City of Seattle, Seattle -King .. County Health Department) total about $1.7 million in 1989. A COMPREHENSIVE PLAN FOR THE FUTURE The Planning ,. Process .. M M State law requires local governments to develop a hazardous waste management plan by June, 1990. All local governments in King County (King County Solid Waste Division, Metro, City of Seattle Office for Long-range Planning and Solid Waste Utility, Seattle -King County Department of Public Health and 28 incorporated cities in the county) have worked together to develop this single, cooperative plan. Public meetings, workshops, focus groups and an opinion survey were conducted through the summer of 1988, as was scoping for the draft environmental impact statement. A Draft Plan/EIS presenting four alternative programs was released in February, 1989. Public response indicated strong support for the two most comprehensive -- and highest cost -- alternatives. Comments received on the Draft Plan/EIS were considered in the development of a hybrid "preferred alter- native," described in this Final Plan/EIS. It maintains a comprehensive approach, but is implemented more slowly than the most aggressive alternative. Before it can be implemented, the Plan must be reviewed by the Solid Waste Interlocal Forum and adopted by the County Council, the Seattle City Council and the Councils of the other incorporated cities in King County. In addition, the Depart- ment of Ecology must review and approve the adopted plan to certify that it meets legal requirements. The adoption and Goal and Objectives 1 SUMMARY 6 ' approval process begins with the publication of this document. .. The various Councils will hold hearings on the Plan through the fall and winter of 1989, providing another opportunity for public comment. .o This plan describes a program that will protect public health and the environment from adverse effects resulting from the improper handling and disposal of hazardous wastes by small quantity generators and households. State guidelines call for local hazardous waste management plans to focus on an initial, five-year period and a long-term, 20 -year period. Objectives are to: • Reduce the input of hazardous substances to municipal waste streams and the environment by a significant, measurable degree; • Minimize accidents resulting in worker and public exposure to hazardous wastes; • Allow solid waste and wastewater facilities to continue to meet environmental discharge standards, even as the population and the number of small businesses increase or as the discharge requirements become more stringent; • Foster an ethic of personal responsibility for waste handling decisions among the public, businesses and ' government. • Meet state guidelines for local hazardous waste plans, including: on-going informational and educational efforts (emphasizing waste reduction) for both the public and businesses; on-site audits of SQGs; a system for collecting HHW; a system for handling SQG wastes (with emphasis on private sector services); and enforcement through local ordinances. 1 M SUMMARY %I Plan Description The Plan is an intensive effort to divert the maximum amount feasible of HHW and SQG wastes from disposal in municipal waste streams and the environment. .. The Plan addresses all aspects of HHW and SQG waste management: HHW education, HHW collection, SQG educa- tion and technical assistance, SQG collection, compliance, and evaluation. These six components emphasize: • Education for waste reduction as the top priority (promotion of practices that reduce, avoid or eliminate the amount of waste generated is a much more cost- effective strategy than is collection and disposal); as much as 44 percent of the HHW projected to be pro- duced can be reduced through product substitutions, reuse and other waste reduction methods. • Development and promotion of convenient and acces- sible collection options for wastes that cannot be reduced; • Technical assistance to help businesses improve their hazardous materials management practices; • Incentives for compliance with federal, state and local regulations; and • On-going evaluation to ensure that program goals and objectives are being met. Specific programs under each component are listed in Table 1. HHW Education IHazzdm5�rn E The HEW education component should raise awareness among the general public and targeted audiences, and promote waste j "'za'dm"aA` reduction. It includes programs such as distribution of informational materials, a central telephone information line, e school activities and promotion of safer products. A HHW education program coordinator will be based at the Seattle -King County Health Department. Additional staff will AfJ fv u wd.•,r o..v�s w.w H..er+ na•n SUMMARY Table 1. PROGRAM ELEMENTS AND IMPLEMENTING AGENCIES 8 "' M PROGRAM ELEMENTS IMPLEMENTING AGENCIES Household Hazardous Waste Education Health • Public Information and Outreach Metro/King CountylSeattle • HHW Telephone Information Line Health • Schools Program King County/Metro Household Hazardous Waste Collection Seattle/King County and Waste Handling • HHW Permanent Collection Facilities Seattlelothers • Mobile HHW Collection Facilities King County • HHW Pickup Service for Homebound Seattle/King County ++� • Targeted Waste Collection and Recycling Seattle/King County • Promotion of Collection Facilities Seattle/King County SQG Education and Technical Assistance Metro • SQG Information Development and Resources Metro • SQG Passive Waste Exchange Health ' • SQG Information Telephone Line Health • SQG Resource Library Metro • Promotion of SQG Waste Reduction, Metro , Recycling and Treatment Programs • SQG Waste Characterization and Metro Treatment Feasibility Program ' • SQG On -Site Consultation Metro SQG Collection and Waste Handling King County , • SQG Mobile Collection Facilities • SQG Auxiliary Collection Facilities • SQG Subsidized Collection ' Compliance Metro • Interagency Regulatory Analysis Committee All • Enhancement of Local Ordinances All • Response Network Metro • SQG Surveys and Audits Health/Metro Evaluation Health/Seattle/Metro I 1 r.. SUMMARY L9 " be spread among a number of local agencies to implement the various education programs. Annual costs for the HHW education component range from $530,000 in 1990 to $1.2 million by 1994. HHW Collection and Waste Handling .. The HHW collection and waste handling component provides services for the safe collection of HHW that cannot be re- duced. Program elements include general HHW collection and target potentially recyclable wastes such as used oil and paints. i 0 0 0 A network of six permanent and three mobile HHW collection facilities is recommended to be established around the county to provide the public with accessible, convenient disposal options for their hazardous wastes (Figure 1). The mobile facilities will accept wastes for a short period of time at a given location then travel to another location, providing col- lection services for outlying areas of the county as well as "filling in the gaps" in the urban/suburban areas. One per- manent and one mobile facility are proposed to be brought on line each year. The HHW collection component will be coordinated by one halftime staff person from King County Solid Waste Division and one half-time staff person from Seattle Solid Waste Utility. Individual facilities will be sponsored or operated by these and other local agencies. .. Collection component costs gradually increase over time, reflecting the increase in service and amount of wastes col- lected. In 1990, program costs are $1.28 million, rising to $3.27 million by 1994. SQG Education and Technical Assistance SQG education and technical assistance programs have two focuses: 1)) accessible, consistent, specific information on hazardous waste management and regulations; and 2) individu- alized technical assistance. Printed materials, seminars and workshops, a telephone information line and a waste exchange will be provided. An on-site consultation program will provide site-specific waste management information for interested 0 D SUMMARY 10 Figure 1. PERMANENT COLLECTION FACILITY r M M r S Wpst`�,s M SUMMARY 11 businesses. Other technical assistance programs will encourage the development of waste reduction processes or technologies and their use by local businesses. An estimated 23 percent of the SQG waste projected to be produced can be reduced through improved materials manage- ment practices. In addition, an estimated 65 percent of the waste that will still need to be collected can be recycled. An SQG education program coordinator, based at Metro, will oversee implementation of this component in close cooperation with the Health Department, other local agencies, the existing Waste Information Network and business associations. Costs for the SQG education and technical assistance compo- nent range from $758,000 in 1990 to $1.3 million in 1994. SQG Collection and Waste Handling The SQG collection component provides a mechanism for ac- cessible collection of SQG wastes. Licensed, private -sector hazardous waste handlers will be encouraged to serve the SQG market. Local governments will oversee the development of and allocate resources for four SQG waste collection facilities in the early years of the plan. These facilities will be operated by private sector companies under contract to local govern- ments. In addition, a disposal subsidy will be offered to qualified SQGs to ease the initial economic burden of hazard- ous waste disposal. Except for this initial subsidy, all costs for waste disposal will be borne by the businesses themselves. The portion of SQG waste that cannot be reduced or recycled must be disposed of through permitted channels -- either r incinerated or landfilled in licensed hazardous waste facilities. The SQG collection component will be coordinated by one full-time staff based at King County who will manage contracts and oversee the subsidy program. Public costs for the SQG collection component range from $381,000 in 1990 to $940,000 in 1994. Public financing of the program phases out completely by 1997, with a cumulative cost of about three percent of total plan costs. M M Compliance 1 q SUMMARY 12 "" Although the Plan emphasizes education and assistance over enforcement, it is recognized that a compliance function is a necessary part of any comprehensive program. The Compli- ance component has two focuses: first, to clarify and strengthen the regulatory framework for HHW and SQG waste management; and second, to strengthen the ability of local governments to identify SQGs and to bring them into compli- ance with local environmental regulations. Programs under this component include: • An Interagency Regulatory Analysis Committee to monitor regulatory changes and to facilitate passage of consistent regulations at the local level; •• • Survey and audit programs to identify SQGs and make them aware of the education and technical assistance programs available to them; and, • A response network to provide a coordinated inspections, referral and follow-up program. Enforcement will be pursued for those SQGs that continue to violate local environmental regulations in lieu of taking advantage of these assistance opportunities. A compliance coordinator, based at Metro, will facilitate interagency activities. Costs for the compliance component will be $650,000 in 1990, rising to $1 million in 1994. Evaluation Given that many of the programs in the Plan are new and un- tested, an extensive evaluation effort is considered essential. The Evaluation component will track program effectiveness, determine how well the programs are being implemented and whether the objectives of the Plan are being achieved. Based on this evaluation, revisions to programs may be necessary within the first five-year implementation period and are expected as part of the fifth year Plan update process. In the first year, an evaluation strategy will be developed for all components of the Plan, including identification of data collection needs. Evaluation will include measures of wastes collected, participants, wastes remaining in municipal waste streams, public awareness, changes in product purchasing and use, changes in business processes, and costs. M C SUMMARY 13 Part-time evaluation coordinators, based at the Health Department, Seattle Office for Long-range Planning and Metro, •• will oversee this effort. Other program coordinators will participate in research design and data collection. Actual research design and subsequent data analysis will be carried .. out by consultants. Costs of the evaluation component are $140,000 in 1990 and .. $125,000 in 1994. M Waste Management Projections and Costs Figures 2 and 3 present projections for hazardous waste reduc- tion and collection over the twenty years of the Plan. The Plan budget is summarized in Table 2. Costs total $3.7 million in 1990, the first full year of implementation, compared to the $1.7 million local governments are spending in this area in 1989. In 1991, program costs will be $5.2 million, rising to $7.9 million by 1994. A large portion of these costs is for the disposal of hazardous wastes collected under the Plan, emphasi- zing the need for maximum effort in waste reduction programs. HOW CAN THE PLAN BE PAID FOR AND IMPLEMENTED? W M 0 W 77 Financing Managing hazardous wastes is not inexpensive regardless of the methods used. Safely handling these wastes is much more ex- pensive in the short term than allowing them to continue to be disposed in the solid waste or sewer. However, in the long run, such preventative activities will keep remedial costs and liabilities to a minimum. Based on public comments and input from local governments, a combination of funding sources is recommended, with major reliance on the state's Local Toxics Control Account and on local utilities through Board of Health fees. This strategy assures that sufficient funding will be available. Authorizing legislation (Initiative 97, passed by voters in November, 1988) specifies hazardous waste plans and programs as one funding priority for the Local Toxics Control Account. ,2000 '0000 8000 O S 5000 1000 2000 0 SUMMARY 14 TOTAL WASTE GENERATED WITHOUT PROGRAM I WASTE REDUCED MUNICIPAL DISPOSAL COLLECTED AND RECYCLED COLLECTED AND DISPOSED 7 5 9 'I !0 'S '9 YEARS Figure 2. PROJECTIONS OF HHW MANAGEMENT 25000 20000 -00 9 5 9 _ 'S YEARS Figure 3. PROJECTIONS OF SQG WASTE MANAGEMENT The top line in each figure shows the amount of hazardous waste projected over the next twenty years assuming no program exists. At the point where the second and third lines meet, the amount of waste remaining in solid waste, wastewater and environment will be negligible. [Note that the vertical scales of the two figures are not identical.] I 1 1 1 1 1 1 1 f 1 1 1 1 1 1 1 1 1 1 Table 2. PLAN BUDGET SUMMARY' 1990 1991 1992 1993 1994 1999 2004 2009 HHW EDUCATION $531,000 731,000 811,000 986,000 1,176,000 1,046,000 1,041,000 1,041,000 HWW COLLECTION 1,281,000 1,893,000 2,423,000 2,821,000 3,269,000 5,536,000 6,791,000 7,665,000 HHW PROGRAM 1,812,000 2,624,000 3,234,000 83. 07,000 4,445,000 6,582,000 7,832,000 8,706,000 SQG EDUCATION 758,000 1,160,000 1,311,000 1,311,000 1,271,000 1,206,000 1,206,000 1,206,000 SQG COLLECTION 381,000 574,000 799,000 958,000 940,000 COMPLIANCE 650,000 728,000 851,000 987,000 1,090,000 1,355,000 1,338,000 1,338,000 SOG PROGRAM 1,789,000 2,462,0(X) 2,961,((X) 3,226,000 3,301,000 2,561,000 2,544,000 2,544,000 EVALUATION 140,0(X) 115,((X) 73,(XX) 73,000 125,000 56,000 63,000 56,000 TOTAL 3,741,000 5,201,000 6,268,000 7,106,000 7,871,000 9,199,000 10,469,000 11,306,000 'in 1989 dollars rounded to nearest thousand. Figures beyond 1994 are gross estimates and are subject to substantial revision at the fifth year (1994) Plan update. SUMMARY 16 as This funding source charges the user of hazardous materials for management and disposal, which is seen by the public as equitable. State assistance in funding Plan implementation is seen by local governments as appropriate, as local hazardous waste management programs are required by state law. While it is difficult to predict the amount of revenue to be received from the Local Toxics Control Account, substantial state funding is assumed. A block grant approach to disbursement of these funds is preferred, with plan implementation funds allocated to those areas with approved, adopted plans based on their percentage of the state's population. us M Even if the maximum level of state funding is obtained, local no funds will still be required. It is recommended that the King County Board of Health and the Seattle City Council (acting as the Seattle Board of Health) assess fees: .r • On billing agents for solid waste collection (whether certificated solid waste haulers or solid waste utilities), and on "self -haulers" using transfer stations or landfills, for 80 percent of the local share. Approximately 80 percent of the hazardous waste in municipal waste streams can be found in solid waste. • On sewage treatment facilities, for the remaining 20 percent of the local share to cover that portion of the hazardous waste in the liquid waste stream. .r These fees would be collected and disbursed by the Seattle - King County Health Department. .r In addition, the fees will be structured so that residential customers will only pay for the HHW portion of the Plan and commercial customers for the SQG portion. r User fees, such as a charge for use of HHW collection facili- ties, may be assessed for program services. User fees can pro- vide only a supplemental funding source, however. The effect of user fees on customer behavior is still unresolved and will be examined as part of the evaluation process. Decisions on whether to charge user fees will be made by individual pro- grams. Any user fees charged will be the same for all users. .n 10 W SUMMARY 17 Fee Levels and Rate Impacts Financing for the Plan is shown in Table 3. The level of fees needed to fund the Plan is shown in Table 4 for solid waste and in Table 5 for wastewater. As noted in the tables, in most cases local governments' 1990 rates or rate proposals already •• include all or a substantial portion of the funds needed to finance the Plan. Rates will most likely increase in subsequent years, assuming that the responsible agencies or haulers elect .w to pass on to their customers any fees enacted by the Board of Health adn the Seattle City Council. Rates could be raised by the cities that manage solid waste disposal contracts, by the .� private haulers who bill directly to their customers (after approval from the Washington Utilities and Transportation Commission), and by Metro and the independent sewer districts that operate wastewater treatment plants. .. Table 3. FUNDING ALLOCATIONS' 1990-1994 (dollars in thousands) 1990 1991 1992 1993 1994 Total Program Cost $3,742 5,202 6,268 7,107 7,871 State Funding 590 590 728 728 869 ■. Local Funding 3,152 4,612 5,540 6,379 7,002 Sewerage Agencies 630 922 1,108 1,276 1,400 Solid Waste 2,522 3,690 4,432 5,103 5,602 'in 1989 dollars r Plan Implementation Three concurrent legislative actions will be required in order for this plan to take effect: All participating jurisdictions must adopt the Plan. Suburban city adoption could be accomplished through the Solid Waste Interlocal Forum Plan Approval Process. SUMMARY 18 Table 4. SOLID WASTE FUNDING (dollars in thousands) ALLOCATIONS AND FEES' 1990-1994 .r 1990 1991 1992 1993 1994 r» HHW Component of $1,268 1,903 2,313 2,762 3,209 Solid Waste Allocation •+ Seattle Contribution 470 706 858 1,024 1,190 ($/accountlyr) (3.36) (5.04) (6.13) (7.31) (8.50) �+ Certificated Haulers 624 850 934 1,131 1,325 ($/account/yr) (2.63) (3.58) (3.93) (4.76) (5.58) .rt PLVs (King County) 174 347 521 607 694 ($/vehicle) (.50) (1.00) (1.50) (1.75) (2.00) .r SQG Component of $1,253 1,788 2,120 2,344 2,395 .r Solid Waste Allocation Certificated Haulers 891 1,335 1,576 1,711 1,762 .� ($/account/yr) (45.22) (67.77) (80.00) (86.85) (89.44) Self -Haul at King 287 359 431 502 502 County Facilities ($/ton) (1.00) (1.25) (1.50) (1.75) (1.75) Self -Haul at Seattle 75 94 113 131 131 Facilities($/ton) (1.00) (1.25) (1.50) (1.75) (1.75) 'in 1989 dollars. This table is for illustration purposes only. Actual amounts may change. The number of to residential accounts for Seattle is estimated at 140,000, and 237,000 for King County. The number of passenger licensed vehicles (PLVs) for King County is estimated at 347,000. The number of commercial accounts is estimated at 19,700. Charging all commercial accounts equally does not reflect the fact that some businesses may generate more hazardous wastes than others. Estimated self -haul tonnage for King County is 287,000 and 75,000 for Seattle. These estimates are held constant over the five years shown although it is recognized that they will need to adjusted on an annual basis. Fees for self -haulers were set to total no more than 29% of the cost of the SQG program, which was the estimated contribution of self -haul to the commercial waste stream. No 'in 1989 dollars. This table is for illustration purposes only. Actual amounts may change. Distribution of sewerage costs is based on 1988 annual average gallons of wastewater treated by all municipal agencies. These figures and relative contributions will change yearly. 'Metro treats 90 percent of the municipal wastewater handled by sewerage agencies in King County. This funding allocation represents approximately 18 percent of the total annual budget for the Plan. 'Sufficient funds are already appropriated in Metro's 1990 budget. Future rate impacts are estimated at $0.16 per million dollars of Metro's share. 'Other sewerage districts or utilities treat 10 percent of the municipal wastewater in King County and will cover approximately 2 percent of the total annual budget for the Plan. SUMMARY 19 Table 5. SEWERAGE FUNDING ALLOCATION AND FEES' 1990-1994 (dollars in thousands) 1990 1991 1992 1993 1994 All Sewerage Agencies $630 922 1,108 1,276 1,400 Metr0' 565 827 994 1,145 1,256 Annual Increase 0 +262 +167 +151 +111 Affecting Future Metro Rates Approximate Metro 0 +40 +30 +20 +20 Rate Impact' Other SW Suburban 24.0 35.0 42.0 48.0 53.0 Federal Way 20.0 29.0 35.0 40.0 44.0 Midway 14.0 20.0 24.0 28.0 30.0 Enumclaw 4.0 6.0 8.0 9.0 10.0 North Bend 1.0 1.4 1.7 1.9 2.1 Duvall 0.8 1.2 1.4 1.7 1.8 S noqualmie 0.7 1.0 1.2 1.4 1.5 Black Diamond 0.4 0.6 0.8 0.9 1.0 V ashon 0.2 0.4 0.4 0.5 0.5 'in 1989 dollars. This table is for illustration purposes only. Actual amounts may change. Distribution of sewerage costs is based on 1988 annual average gallons of wastewater treated by all municipal agencies. These figures and relative contributions will change yearly. 'Metro treats 90 percent of the municipal wastewater handled by sewerage agencies in King County. This funding allocation represents approximately 18 percent of the total annual budget for the Plan. 'Sufficient funds are already appropriated in Metro's 1990 budget. Future rate impacts are estimated at $0.16 per million dollars of Metro's share. 'Other sewerage districts or utilities treat 10 percent of the municipal wastewater in King County and will cover approximately 2 percent of the total annual budget for the Plan. SUMMARY to 20 r • The King County Board of Health must pass a rule that 09 sets fees and directs the Health Department to collect and disburse the fees according to an annual implemen- tation plan approved by both the County Board of .r Health and the Seattle City Council. The rule will also establish a Management Coordination Committee. The Committee, composed of senior staff (e.g., utility .r managers) representing the major participating govern- ment entities (King County, the Health Department, Metro, the City of Seattle and suburban cities) will no oversee Plan implementation. • The Seattle City Council (acting as the Seattle Board of .r Health) must pass an ordinance with the same requirements. me In addition, Ecology must approve the adopted Plan to ensure that it meets state guidelines. no Seattle, suburban cities, King County, Metro and the Health Department will be involved in plan implementation (Table 1). All participating jurisdictions, in voting to adopt the final plan, rr will agree to take on certain responsibilities and implement certain programs, or will clearly delegate such responsibilities to other agencies. Commitments will cover at least the first r five-year period, at which point a major evaluation of the program will occur. Suburban cities have signed an Interlocal Agreement with King .r County, whereby the County assumes responsibility for planning and disposal of HHW and SQG hazardous wastes for go the suburban cities (Appendix B). After 1990: • The Management Committee will recommend an annual implementation plan and budget to the County Board of Health and the Seattle City Council. Both bodies will approve an annual plan and budget, r adjust fees as needed, and instruct the Health Department to enter into the necessary interlocal agreements, contracts or memoranda of understanding to , see that the year's work is completed. M r- SUMMARY 21 • The Health Department will collect the fees prepare P � P P necessary agreements, and disburse funds, per the annual 1 implementation plan. • The other parties in the contracts or agreements will follow the procedures necessary to accept funds in this manner. • The Management Committee will be supported by a staff committee composed of program coordinators and other program implementation staff. The staff com- mittee will track implementation and report to the Management Committee. For 1990, King County Solid Waste Division, Seattle Solid Waste Utility, Metro and the Health Department will be largely responsible for program implementation, primarily because these agencies contributed to plan development and were able to incorporate plan programs into their 1990 budgets. It is expected that, after 1990, other jurisdictions will become more Iactively involved in Plan implementation. Suburban cities will be represented on the Management Coor- dination Committee. In addition, certain jurisdictions may elect to participate in Plan implementation by sponsoring one or more program elements. For example, a suburban city may choose to site a permanent collection facility within its boundaries, actively participate in public education programs, or join in survey or audit programs of local businesses. Many suburban cities will participate in the response network, enhancement of local ordinances and the interagency regulatory analysis committee. The private sector has a major role in Plan implementation. ' Many education programs could be carried out by nonprofit education groups or consultants. SQG education and technical assistance efforts rely on the voluntary participation of busi- nesses and trade associations. SQG collection will rely on private companies for the operation of collection sites, as well as transporting and subsequent handling of hazardous wastes. At least some of the HHW collection services will be contracted out. SUMMARY 22 r The State of Washington has a critical role to ensure that this .r plan is fully implemented. Funding through the Local Toxics Control Account is essential. State programs in the areas of waste reduction, targeted waste, and enforcement and compli- ance are important partners with local efforts. Product labeling would be better dealt with at the state level. And, up front, the state must approve this plan in order to meet state law and .r to ensure subsequent support. W WHAT ARE THE POTENTIAL ENVIRONMENTAL IMPACTS AND HOW CAN THEY BE MITIGATED? The primary impacts of the Plan will be positive for the environment as well as human health and safety. The Plan will result in a reduction in the amount of hazardous waste generated and an increase in safe handling of the hazardous wastes still produced. Potential negative impacts relate to the hazardous waste collection and handling activities proposed in the Plan. These include collection facility siting and design, transporting of wastes to hazardous waste handling facilities, worker and public safety, and the amounts of waste remaining in municipal waste streams. Site specific environmental review will occur during facility development, and will follow State Environmental Policy Act (SEPA) guidelines. .o siting Siting of HHW or SQG collection facilities, whether permanent or mobile, will avoid sensitive areas such as wetlands, shore- lines, 100 -year floodplains and earthquake faults to the extent No practicable, and will go through local permitting and land use reviews. Consistency with local zoning codes will minimize so conflicts between proposed sites and adjacent land uses. Desi n A collection facility will most likely consist of one or more "r hazardous materials storage containers on an impervious sur- face. Each facility will be equipped with a variety of safety features such as spill containment, fire and explosion protection and ventilation. Wastes brought to the site will be sorted for compatibility, packed and temporarily stored. go R 1 1 i L1 R_ SUMMARY 23 Transport Collected wastes will be regularly and frequently removed by a licensed hazardous waste transporting service and brought to a licensed hazardous waste handling facility for reprocessing, treatment or disposal. Preferred transportation routes for the collected wastes will be identified for each site to minimize adverse impacts. Contingency plans for spills will be developed for each site and transporter. Health and Safety VISION OF THE FUTURE W Health and public safety will be major considerations in site design and operation. Potential exposure to hazardous chemi- cals will be minimized through facility design, operating plans, contingency plans, safety training, exposure monitoring and emergency procedures. We envision a future of hazardous chemical use that will be very different from today. Implementation of this Plan will set us on the road to this future. Hazardous waste reduction and proper hazardous waste management will be matters for civic pride in King County neighborhoods, cities, and rural areas. Solid waste facilities and sewage treatment plants will be essentially free of hazard- ous chemicals, and storm drains, streams, and water bodies will no longer be viewed as appropriate repositories for hazardous liquid wastes. Businesses and residents alike will be proud of the creative solutions they have found to the problems of hazardous chemical use. It is the year 2010. When a King County resident goes to the store, he or she is aware of the potential hazards of products she may purchase. Wherever possible, he or she chooses the least hazardous products available to perform her cleaning, pest control, or home maintenance tasks. Due to this consumer preference, manufacturers are competing to put less toxic or hazardous items on the shelves. Product labels indicate level of hazard and proper disposal methods. Retail outlets meet customer demand by providing information on less hazardous products and prominently displaying them. As413SED Moro A P poi �v U w C9 � a 0 SUMMARY 24 Some jobs still require the use of products that may present some risk. These products are available in small sizes -- just enough to complete the job -- to avoid the generation of un- necessary waste, risks from extended storage, or unwarranted use. Car owners who do their own maintenance are careful not to spill used oil, brake fluid, or antifreeze onto the street or pour them down the storm drain. Used oil is readily recycled at numerous local outlets. Other wastes are collected for disposal at special facilities within a few miles of each resident's home. The use of chemical pesticides has diminished significantly. Gardeners are educated in alternative methods for preventing or controlling pests. Values are shifting so that using hazardous chemicals on a lawn is seen as less desirable than the appearance of occasional weeds. Urban pesticide runoff no longer contaminates our local lakes and streams. Because future King County residents own so few hazardous chemicals, fewer poisonings occur, and children exploring under the sink are likely to find nothing more toxic than vinegar. Businesses, too, are well educated about the proper manage- ment of hazardous wastes, and no longer toss them in the garbage or down the drain. Companies that generate the least amount of these hazardous wastes are at a competitive advan- tage, since disposal costs are high and have become a routine part of doing business. Workers take an active interest in careful waste management and fewer workers are injured each year from exposure to hazardous chemicals. Forward-looking companies take advantage of technical assistance opportunities. A regional library and database system is available to help businesses keep up to date on the latest waste reduction technologies. Businesses themselves have become significant sources of new and innovative ideas for waste reduction. Gas stations, print shops, dry cleaners, and other establishments store the small quantities of hazardous wastes still generated in well-contained, well -protected areas, and dispose of them through the services provided to address their special needs. Barrels of accumulated wastes and ignorance of proper handling or disposal methods are a thing of the past. 10 do .r we so no .r J WWIW r7 am �W bw SUMMARY 25 Businesses are proud of their careful waste management activities, and attract customers by advertising their involvement in waste reduction and recycling. Some busi- nesses even find the focus of their activities changing as customer preference changes. Pest control operators, for example, are providing a valuable service to the community ho with integrated pest management practices. The children of the 1990s and beyond will become the adults of a generation that accepts proper management of hazardous chemicals as a fact of daily life, whether in the home, in the workplace, or in the management of large industries. lJ LJ i 1 d 7 R I I I r Im SECTION 1 INTRODUCTION 1-1 r The Local Hazardous Waste Management Plan and Envi- ronmental Impact Statement (Final Plan/EIS) describes a comprehensive program for managing hazardous wastes ' generated in small quantities by households and businesses in King County. The Final Plan/EIS proposes regionally - coordinated programs that will protect the environment by decreasing the amount or toxicity of hazardous waste disposed of in municipal solid and liquid waste streams. 1 THE ISSUE J r 1 Both the King County and City of Seattle Solid Waste Comprehensive Management Plans refer to the Local Hazardous Waste Management Plan for guidance in managing these hazardous wastes. The Final Plan/EIS is designed to manage these wastes according to the priorities established by state legislation. Highest priority is given to waste reduction. The Plan encourages households and businesses to reduce the amount of hazardous products used and wastes generated by changing use and purchasing practices. Recycling and treatment of wastes are emphasized for remaining wastes, with collection for disposal the lowest priority. Many products regularly used in the home and workplace contain hazardous chemicals. If mishandled, hazardous chemicals pose a risk to human health and the environment. These chemicals can be corrosive, ignitable, toxic or reactive, characteristics that mean both the product and the resulting waste require special handling. Cleaners, paints, pesticides and automobile products are examples of household products that contain hazardous chemicals; when thrown away, these products become house- hold hazardous waste (HHW) (Table 1-1). Households are exempt from state and federal hazardous waste regulations. Some industries and commercial businesses also produce small quantities of hazardous wastes in the course of doing business. Dry cleaners, print shops, auto repair shops and medical labs are examples of businesses that typically generate small amounts of hazardous wastes (Table 1-2). A generator of SECTION 1 INTRODUCTION Table 1-1. EXAMPLES OF HAZARDOUS HOUSEHOLD SUBSTANCES' REPAIR AND REMODELING Adhesives, Glues, Cements Roof Coatings, Sealants Caulkings and Sealants Epoxy Resins Paints Solvents and Thinners Paint Removers & Strippers GARDENING Insecticides Fungicides Rodenticides Molluscides Wood Preservatives Moss Retardants Herbicides Fertilizers CLEANING AGENTS Oven Cleaners Degreasers & Spot Removers Toilet, Drain & Septic Tank Cleaners Polishes, Waxes & Strippers Deck, Patio, Chimney Cleaners Solvent Cleaning Fluid err 1-2 .m AUTO. BOAT, EQUIPMENT MAINTENANCE Vehicle Batteries Waxes & Cleaners Paints, Solvents & Thinners Additives Gasoline Flushes Auto Repair Materials Motor Oil Diesel Oil HOBBY AND RECREATION Paints, Thinners and Solvents Chemicals (including Photo & Pool) Glues and Cements Inks and Dyes Glazes Chemistry Sets Bottled Gas White Gas Charcoal Fluid Household Batteries Household hazardous wastes are any discarded items from the above hazardous household hazardous substances list. 'Planning Guidelines for Local Hazardous Waste Plans, Washington State Department of Ecology, July 1897. r at No r7 .r rJ M r-, pi SECTION 1 INTRODUCTION Table 1-2. EXAMPLES OF SMALL QUANTITY GENERATOR WASTE CATEGORIES AND BUSINESS TYPES' SQG waste categories include (but are not limited to): Pesticides Dyes Paints Thinners Solvents Cleaning fluids Coolants Oils Other petroleum products Photographic or X-ray developers Acids Bases Aerosols Batteries Alcohols Waxes Adhesives Inks Flammable materials Sludges SQG business types likely to produce wastes of interest include: Drycleaners Automotive service and repair shops Automotive body and paint shops Electroplaters Printing and reproduction shops, photo labs Hospitals, medical and dental facilities Pesticide chemical applicators Public works, school and utility shops Construction companies Marine repair and service shops Paint shops Woodworking and furniture repair shops Machine shops Beauty salons Miscellaneous equipment repair and maintenance 'Analysis performed by Metro Industrial Waste Section, 1988. 1-3 SECTION 1 INTRODUCTION 1-4 GOAL AND OBJECTIVES r hazardous waste who produces less than 220 pounds' of No hazardous waste per month falls below the state regulatory limits and is categorized as a Small Quantity Generator (SQG) (Figure 1-1). SQGs are conditionally exempt from regulation r+ by the state and federal governments. The Plan addresses proper management of the exempt hazardous wastes from both households and businesses? .o These hazardous wastes can ultimately end up in municipal solid waste, wastewater and the local environment. Although r generated in small quantities, cumulative amounts of these wastes entering the municipal waste stream may have adverse impacts on the environment and public health. New chemical so technologies, continued use of hazardous products, and population growth in the King County area mean that the amount of these hazardous wastes generated will increase in no the future, unless waste reduction programs are instituted. In 1988, an estimated 19,000 tons of HHW and SQG hazard- ous wastes were included in municipal waste streams in King County; 16,000 tons entered the solid waste stream and 3,000 tons were disposed of in the sewer system (Local Hazardous „■, Waste Plan Issue Paper; Appendix C). In addition, unquantifi- able amounts of hazardous chemicals are dumped every year onto the ground and into storm drains where they eventually enter local waters. The 1985 amendments to the Washington State Hazardous of Waste Management Act require local governments to develop plans to manage these wastes. King County local governments are working together to develop a comprehensive program to r manage hazardous wastes entering municipal waste streams and the environment. The overall goal of the Local Hazardous Waste Management Plan is to protect the environment and public health from the adverse effects of improper handling and disposal of HHW and SQG hazardous wastes. 'Certain designated Extremely Hazardous Wastes are regulated at 2.2 pounds. W 2For a formal definition of HHW and SQG waste see Appendix B. rJ up SECTION 1 INTRODUCTION 1-5 HAZARDOUS WASTES CORROSIVE IGNITABLE READ HCUSEHOLD WASTES COMMERCIALAND INDUSTRIALWASTES categorically exempt less than 220 pounds greater than 220 pounds "H H` '' per month or batch per month or batch ''SQG" UNREGULATED CONDITIONALLY FULLY EXEMPT REGULATED some extremely hazardous wastes are regulated down to 2.2 pounds or less. Figure 1-1. UNREGULATED, CONDITIONALLY EXEMPT AND REGULATED HAZARDOUS WASTE GENERATORS Hazardous wastes are generated by industries, businesses and households. Current regulations address wastes generated in amounts greater than 220 pounds per month. The Local Hazardous Waste Management Plan will address household and conditionally exempt hazardous wastes. rw r SECTION 1 INTRODUCTION 1-6 The Plan is designed to achieve the following objectives: •r • Reduce the input of hazardous substances to municipal waste streams and the environment by a significant, .rr measurable amount. • Minimize accidents resulting in worker and public ,r exposure to hazardous waste. • Emphasize waste management strategies that give aw priority to waste reduction and recycling. • Foster an ethic of personal responsibility for waste management decisions among the public, businesses and government. • Be comprehensive; address all aspects of the issue, including all areas of the county, all waste streams and targeted audiences. • Emphasize education over enforcement as a means of attaining compliance. .o • Be flexible; allow for changes in the legal and planning environment. • Have the practical resources and support to ensure implementation while recognizing the unique capabilities .r and limitations of different governments. • Involve all key parties, public and community organi- zations, state and local public agencies, small businesses and hazardous waste management companies in Plan development and implementation. THE PLANNING PROCESS In July, 1987, the Department of Ecology (Ecology) issued Planning Guidelines for Local Hazardous Waste Plans. Each local government or combination of local governments is required to prepare a plan based on these guidelines. King County agencies have chosen to use a cooperative planning strategy. Five lead agencies are participating in the development of the King County Local Hazardous Waste am .r t�. SECTION 1 INTRODUCTION 1-7 Management Plan: King County Department of Public Works Solid Waste Division; City of Seattle Office for Long-range Planning and Solid Waste Utility; Seattle -King County Department of Public Health; and Metro's Water Pollution Control Department. Other supporting participants include the Suburban Cities Association and Metro's Environmental Planning Division. Development of the plan was divided into two tasks. The first Ocal dou" W„te task was to research and write an Issue Paper that documents ylana8 e'oert Pla Co_nrl the current and future conditions affectingthe management of for SeaUle Ktng small quantities of hazardous waste in King County. The Issue Paper was completed and available for public comment in June, 1988. Section 2 of this document describes the region and summarizes the issues, problems and needs identified in the Issue Paper. Local Hu aste Uanage�ent Plan for Seatda King Count' owt Ptan ti` v and Sfaferon�en4l (^'Pact Gent Sa+u Q�.� �y Haaaidoua W+ate in Searnc.Kins r tha �ar,n R'gwn Fcb�+ary, 19� The second task was development of the management plan itself. A Draft Plan/EIS was developed following the publica- tion of the Issue Paper. The Draft Plan was a response to the needs identified in, and comments received in response to the Issue Paper, as well as public participation activities. Individual "program elements” were developed to address these needs and comments (Appendix A). These program elements were measured against a set of criteria to assess how well each would contribute to the goal and objectives of the plan. Program elements found acceptable were combined to create the four plan alternatives presented in the Draft Plan/EIS. Three of the four plan alternatives were evaluated against the objectives as essential to attaining the goal of this plan; the fourth alternative projected the effect of maintaining current levels of effort until 2009.' Briefly, the four alternatives proposed in the Draft Plan/EIS were: • Maximum Diversion Alternative: an intensive, compre- hensive effort to divert 100 percent' of these wastes 'Appendix A contains a detailed description of the plan development methodology. ' Percent diversion is defined as the amount of hazardous waste that does not enter the municipal waste streams or the environment because: a) the waste is not created in the first place (waste reduction), or b) the waste is managed in a way that protects the 6, SECTION 1 INTRODUCTION 1-8 1 PUBLIC PARTICIPATION from municipal solid and liquid waste streams in the .o shortest period considered possible: 10 years for HHW and 15 years for SQG wastes. The cumulative costs of the Maximum Diversion Alternative were an estimated a+ $207 million over the 20 -year life of the plan, resulting in an average cost per ton of waste diverted of $573. ■r • Phased Implementation Alternative: a less intensive, though still comprehensive, effort to divert 100 percent of both HHW and SQG wastes by the twentieth year of W the plan, at a cumulative cost of $161 million or an average cost per ton of $664. as • Fifty Percent Diversion Alternative: this alternative would have resulted in diversion of 50 percent of HHW and SQG wastes in twenty years, at a cumulative cost VW of $81 million or an average cost per ton of $658. • Status Quo Alternative: described the effect of main- ow taining the current level of effort (1989) to manage these wastes over twenty years. By 2009, the Status Quo Alternative would divert 8 percent of both HHW WN and SQG wastes from municipal waste streams. The cumulative cost of the Status Quo Alternative was an estimated $33 million, yielding an average cost per ton of of waste diverted of $1773. Based on comments received from the public and Suburban Cities representatives, a single "preferred alternative," was formulated and is presented as the Plan in this document (Section 3). s, The public was given opportunities to comment as the plan was developed.' All documents were issued in draft form for public review. Special efforts were made to elicit public comment, including meetings, workshops, a public opinion survey and focus group discussions. Public comments were M r environment and the public health, either through collection and recycling, treatment or disposal. W 'Appendix D is a summary of the public participation process. ar 40 rs W SECTION 1 M aw 1 i u INTRODUCTION 1-9 incorporated into this Final Plan/EIS, and responses to comments are contained in Section 5. Two workshops were offered to invited representatives from businesses, environmental and community organizations, and state and local agencies at critical stages of plan development. The first workshop was held on June 15, 1988, to enlist participation and ensure that the full range of conditions and concerns would be addressed in the plan. The second work- shop was held October 11, 1988, to continue the input from key organizations and agencies in plan development. In June 1988, after release of the Issue Paper, public meetings were held in north, south and central King County. The Issue Paper was available for public comment from June through August 1, 1988. Scoping for the Draft Plan/EIS was held August 1-22, 1988. Also during August, 1988, a telephone survey and two focus group discussions were conducted. One focus group was held for households and the other for small quantity generators. The household focus group was attended by eight King County residents selected at random. The SQG focus group was comprised of nine representatives from SQGs. The telephone survey polled 600 residents in Seattle, unincorporated and incorporated King County. The survey and focus groups allowed: 1) a determination of the level of public awareness of the issues; 2) identification of problems and needs, including information on the kinds of services and programs the public wanted; and 3) development of the Draft Plan alternatives. The Draft Plan/EIS was released for public comment in February 1989. The King County and Seattle Solid Waste Citizens Advisory Committees and Metro's Citizens Water Quality Advisory Committee were briefed on the Draft Plan, as it was developed and had the opportunity to comment. Three public meetings were held in north, south and central King County, in March, 1989 to elicit public response to the Draft Plan/EIS. In June, 1989, a workshop was held for suburban cities staff to elicit their concerns and assess their willingness to participate in Plan implementation; thirteen cities were represented (See Supplement to Appendix D). SECTION 1 THE PLAN N INTRODUCTION 1-10 The environmental review process for the plan is in accordance go with the State Environmental Policy Act rules. This Final Plan/EIS serves as the programmatic (non -project) Final Environmental Impact Statement for the plan. .. Public comment supported adoption of the Maximum Diversion .► or Phased Implementation Alternatives presented in the Draft Plan. Local governments were also supportive of a significant level of effort for this program, although there was a concern r that costs not place an undue burden on King County citizens and businesses. Utility costs are rising quickly throughout the County for a variety of reasons, such as the need to institute r solid waste recycling programs and secondary sewage treat- ment. Funding of the Local Hazardous Waste Management Plan will contribute to those increases. rf Some respondents also indicated that a goal of 100% diversion was not practical and that a plan specifying 100 percent no diversion was guaranteed to fail. However, no lower goal could be identified as any more reasonable. .n The Plan presented in Section 3 is a hybrid of the Maximum Diversion and Phased Implementation alternatives. Under the Plan, the comprehensive approach to HHW and SQG waste management is maintained, but programs are brought on-line more slowly than in the Maximum Diversion Alternative resulting in lower overall costs for the first 5 years. In, addition, the Plan is not expected to result in diversion of 100 percent of the waste; rather, it will result in diversion of waste to the maximum extent feasible after 12 years for HHW and 20 years for SQG wastes. Over 20 years, the average cost per ton of waste diverted is $568. SCHEDULE FOR COMPLETION This Final Plan/EIS will be submitted to the State Department of Ecology for approval and to the Interlocal Forum and local councils for adoption during 1989. Implementation will begin as soon as budgets allow, beginning with the 1990 budget cycles of the key implementing agencies. No W r, r. M SECTION 1 INTRODUCTION 1-11 ORGANIZATION OF THE FINAL PLAN/EIS r7 7 UW 0 M M Section 2: Background provides an overview of the local environment, projections of unregulated hazardous waste generation over the life of the plan (20 years), current hazardous waste management practices and programs, and the roles and responsibilities of local and state government agencies. Existing problems and needs are identified. Section 3: Plan Description presents the proposed program, implementation and financing mechanisms, and the roles of the major participants in Plan implementation. Section 4: Affected Environment, Potential Impacts and Mitigation Measures describes environmental impacts that may occur with plan implementation. Mitigation measures to minimize the potential impacts are identified. Section 5: Responsiveness Summary contains responses to public comments received on the Draft Plan/EIS. Appendix A: Program Elements describes plan development methodology and the "program elements," the building blocks of the Plan. Appendix B: Technical Information contains background information to supplement the Final Plan/EIS, such as detailed budget projections. Appendix C: Issue Paper contains the Issue Paper published June, 1988, and is bound as a separate document. Appendix D: Public Involvement Documents contains summaries of all public involvement activities, bound as a separate document. (A supplement to Appendix D can be found following Appendix B in this document.) d 11 wo W SECTION 2 BACKGROUND INFORMATION 2-1 This section summarizes what is known about the existing and potential impacts of household hazardous wastes and small quantity generator waste on health and safety and the environment. More detail can be found in the Issue Paper (Appendix Q. This section summarizes the findings of the Issue Paper and the results of further analyses undertaken since the Issue Paper was published. In addition to the environmental impacts, the health and safety implications of current management of these wastes are described. Upcoming regulatory changes in waste management requirements are assessed to determine whether current methods of handling HHW and SQG wastes would be adequate in the future. to LOCATION AND SETTING to ,rr aw Natural Environment King County encompasses about 2,140 square miles (1,366,000 acres) with elevations ranging from sea level to 8,000 feet. The county is bounded by Puget Sound and Kitsap County on the west, Snohomish County to the north, the central peaks of the Cascade Mountains and Kittitas County to the east, and the White and Green Rivers and Pierce County to the south. Approximately 50 percent of the county, mostly the mountainous eastern portion, is federal or commercial forest land. The Local Hazardous Waste Management Plan applies to all of King County. Figure 2-1 shows the incorporated cities and towns of King County. King County's water resources are plentiful. One goal of the Plan is to protect these resources from the effects of inappropriate disposal of HHW and SQG wastes. VW Lake Washington and Lake Sammamish are the largest freshwater lakes in the county and contain a variety of fish, "O including important salmon runs. These lakes are also used intensively for recreational purposes. The three largest rivers in King County are the Cedar River, which empties into Lake Washington, and the Snoqualmie and Green/Duwamish Rivers, which empty into Puget Sound. +r Many of these rivers serve as municipal water sources, provide habitat for fish, or are used for hydroelectric power generation. or M SECTION 2 BACKGROUND INFORMATION 2-2 PUGETSOUND Figure 2-1. Lake Forest Bothell Park L I Normandy. Park Des Mioines at SNOHOMISH CO, an Skykomish —0- 1?j✓ Duvall Carnation Snoqualmie Issaquah ........ . North Bend Black 0 1 a m on d EnumclaA, scale I 5 Miles PIEFCE CO. KING COUNTY AND INCORPORATED CITIES AND TOWNS MR SECTION 2 BACKGROUND INFORMATION 2-3 In King County, groundwater is also tapped for public and private water supplies, irrigation, and industrial use. Most groundwater used for drinking water is found in relatively shallow glacial deposits that could be contaminated by surface disposal activities. "' The climate in King County, while generally temperate in the lowlands, can range from below freezing to nearly 100 degrees Fahrenheit. Average annual precipitation ranges from about 35 "" to 50 inches in the lowlands, 75 inches in the foothills, to 100 to 200 inches in the Cascades. Temperature and precipitation may influence hazardous waste disposal practices and con- es sequent environmental effects. For example, rain may wash wastes into soils and water systems, affecting operations of both landfills (by creating leachate) and sewage treatment as plants. The season and weather may also influence the public's use of hazardous substances such as solvents for stripping paints, antifreeze added to the car radiator, or .. insecticides. 1W Built Environment The type and quantity of HHW and SQG wastes generated in .. a region are influenced by population, population density, number of small businesses and other factors. Population At the present time, King County represents about 31 percent of the total state population. As of April 1, 1988, the total population of King County was 1,413,900. Of this total, approximately 60 percent live in incorporated cities and towns, w ( I p� ®i and the remaining 40 percent live in unincorporated areas � LQ (Office of Financial Management, 1988). The County's 29 incorporated cities and towns cover more than 220 square miles. Seattle, Bellevue, Renton, Redmond, Auburn and Kent occupy 80 percent of this area or approximately 180 square miles. Table 2-1 lists the incorporated towns and cities of King County and their 1988 populations (PSCOG, 1988). Population .. Density The proportion of single family units versus multifamily units will influence the type and quantity of household hazardous waste generated in King County. Families living in single family residences generate different types and quantities of waste than those living in multifamily homes; different M SECTION 2 BACKGROUND INFORMATION Table 2-1. 1988 POPULATION OF INCORPORATED CITIES AND TOWNS IN KING COUNTY' 2-4 Aw King County (Total) 1,413,900 Unincorporated 571,629 Incorporated 842,271 Algona 1,655 Auburn 30,790 Beaux Arts 293 w Bellevue 85,180 Black Diamond 1,330 Bothell (part) 9,850 Carnation 1,250 Clyde Hill 3,030 Des Moines 14,120 .r Duvall 1,910 Enumclaw 6,260 Hunts Point 505 „w Issaquah 7,170 Kent 32,350 Kirkland 35,820 Lake Forest Park 2,770 Medina 2,950 Mercer Island 20,690 Milton (part) 545 Normandy Park 6,130 North Bend 2,275 Pacific 3,320 Redmond 31,710 Renton 36,940 Seattle 495,900 .rr Skykomish 233 Snoqualmie 1,515 Tukwila 4,760 Yarrow Point 1,020 so The population of King County in 1988 is estimated to be 1.4 million people, of which 60 percent live in the 29 incorporated cities and towns. so 'Puget Sound Council of Governments, 1988. ad SECTION 2 Population Growth ow 1# am I t 'W -W Awtlt dM MR BACKGROUND INFORMATION 2-5 programs may be required to reduce the amount of waste from these two sources. In 1988, King County contained approximately 617,000 housing units. Of the total housing stock, approximately 59 percent were single family units, 38 percent multifamily units, and three percent were mobile homes. Many suburban cities, however, had a higher proportion of multifamily units. Unincorporated King County had fewer multifamily units than the county as a whole and more mobile homes. The City of Seattle has 52 percent single-family and 48 percent multifamily homes (Moehring, 1988). Figure 2-2 shows 1980 population density and distribution in King County. For King County as a whole, population growth during the decade from 1970 to 1980 was 9.5 percent. Total population in the county increased from 1,269,898 in 1980 to 1,413,900 in 1988, a 11.3 percent gain for the eight-year period (PS -COG, 1988). During this period, population increased faster in unincorporated areas of the county than in incorporated ones. This trend is expected to continue at least through the year 2000. By 2000, unincorporated areas are expected to have about one-half of the County's population (King County, 1987). Table 2-2 shows population projections for Seattle and King County through the year 2000. Land use estimates and forecasts for King County indicate that the county has and will continue to experience a rapid rate of growth to the year 2000. The amount of land under residential uses is projected to increase by 122 percent between 1970 and 2000. Land used for employment uses is forecasted to show a similar gain, increasing by 121 percent. Meanwhile, the amount of vacant, developable land is expected to decrease by 44 percent in the 30 -year period (PSCOG, 1984). Table 2-3 shows estimated and projected land use 1970-2000. Economy In the past, the economy of the Puget Sound area has been dominated by the resource sector (forestry, fishing, and mining) and the manufacturing sector (wood products, food products, and transportation machinery). The number of people s employed in the resource and manufacturing sectors has increased, with the exception of agriculture. However, these .. SECTION 2 BACKGROUND INFORMATION 2-6 �. Scale 1:300,000 Figure 2-2. 1•�: ice•.: �':�.�`' :::tea: •. :5:: `; , Vic:) � '.":��,.7.tu ..�.':::\:r •. e•4. POPULATION DENSITY AND DISTRIBUTION (Adapted from PSCOG, 1982) One dot represents 100 people. SECTION 2 BACKGROUND INFORMATION 2-7 Table 2-2. POPULATION ESTIMATES AND PROJECTIONS FOR SEATTLE AND KING COUNTY' 'Puget Sound Council of Governments, 1988 Table 2-3. ESTIMATED AND PROJECTED WES'T'ERN KING COUNTY' LAND USE BY TYPE (1970-2000)2 1970 1980 1990 2000 2020 Seattle 530,831 493,846 496,254 507,068 521,720 Eastside King County 197,253 216,999 355,424 457,802 626,005 Shoreline 64,532 62,067 64,076 67,387 70,059 Green River Valley 98,177 106,346 133,390 156,581 192,863 Southwest King County 164,123 176,989 209,974 241,553 287,505 Southeast King County 81,109 122,462 162,159 217,514 344,025 Other King County 23,562 31,040 39,719 49,614 72,567 Total 1,159,587 1,209,749 1,460,996 1,697,519 2,114,744 'Puget Sound Council of Governments, 1988 Table 2-3. ESTIMATED AND PROJECTED WES'T'ERN KING COUNTY' LAND USE BY TYPE (1970-2000)2 'Total acreage excludes easternmost areas of King County. 2Puget Sound Council of Governments, 1988 'Indicates acreage of land that is physically developable according to current standards and policies of local governments. 'Includes land that is not physically buildable, such as streets, parks and similar land uses. MW 1970 1980 1990 2000 Total Land (acres) 606,854 606,854 606,854 606,854 Residential Land 59,706 86,977 105,780 122,797 Employment Land 17,913 24,651 33,355 44,084 be Vacant Developable' 266,817 208,561 175,084 140,845 Balance' 263,138 286,665 292,635 299,128 'Total acreage excludes easternmost areas of King County. 2Puget Sound Council of Governments, 1988 'Indicates acreage of land that is physically developable according to current standards and policies of local governments. 'Includes land that is not physically buildable, such as streets, parks and similar land uses. MW SECTION 2 BACKGROUND INFORMATION 2-8 JW sectors employ a decreasing share of the work force because of the increasing importance of the service sector in the regional economy. Growth in the service sector is particularly evident in King County, where business, health and legal services have +• become almost as large in employees as the resource and manufacturing industries. Since 1982, this sector has grown by more than 10,000 jobs per year. Many of these jobs are in ,yr start-up businesses and smaller, expanding enterprises. The geographic distribution of employment growth is as 14 follows: fifty-one percent of the growth in employment is expected to be in Seattle, 33 percent in suburban cities, and only 16 percent in unincorporated areas. By 2000, „` unincorporated areas are expected to have approximately one- sixth of the county's jobs as well as one-half of its population. In March, 1987, there were in King County approximately 34,500 businesses that employed fewer than 50 persons, i.e., "small businesses" as defined by Washington State Employment Security (Thomas, personal communication, 1989). Based on "� analysis of SIC codes, it is estimated that about 20,000 businesses are possibly small quantity generators (Appendix B). as Zoning for Hazardous Waste Facilities rw State law (RCW 70.105.225) required all local jurisdictions to amend their zoning ordinances by November, 1991 to allow hazardous waste treatment and storage facilities in every zone "= where handling of hazardous substances is permitted. Most larger jurisdictions in King County have received approval for their adopted ordinances or conditional approval for ordinances in the process of being adopted. Most communities permit on- site treatment and storage in commercial and industrial zones, and treatment and storage off-site in industrial zones. Some so communities require conditional use or special permits. Examples of these designations are included in Appendix B. EXISTING WASTE FACILITIES ■w Existing waste handling facilities are described briefly, since much HHW and SQG waste is currently disposed of in the trash or into the sewer. Facilities that inadvertently handle M 10 VOL ow SECTION 2 BACKGROUND INFORMATION 2-9 Im HHW and SQG waste include solid waste transfer stations, landfills and sewage treatment plants. ■. Solid Waste Facilities .p No ou Uft op All the solid waste in King County that is not recycled currently goes to landfills. In addition to the Cedar Hills Landfill, which accepts over 95 percent of the region's municipal solid waste, small landfills operate on Vashon Island and in the rural east county as shown in Figure 2-3. Most of these small landfills are being phased out. Duvall landfill has closed; Cedar Falls landfill will close by the end of 1989. Enumclaw and Hobart landfills are scheduled to close in 1992 and 1994 respectively. There are also ten operating transfer stations within the County and one drop box for solid waste at Skykomish. In 1988, approximately 1.7 million tons of municipal solid waste were generated in King County (R.W. Beck and Associates, 1988). According to the King County Solid Waste Management Programmatic EIS, 1.3 million tons of garbage were disposed of in 1987. The EIS projected a recycling rate of 15 percent in 1987. Assuming nothing is done to affect the rate of solid waste generation, population growth alone in King County would result in increased solid waste generation. Total tonnage of solid waste generated is projected to increase to 1.8 million by 1994, 2.1 million by 1999, and 2.8 million by 2009 unless successful recycling programs are implemented (King County Solid Waste Division, 1988). Most of the solid wastes collected at transfer stations and rural drop boxes operated by King County and the City of Seattle are transported by private disposal operators. Residential, commercial, and many industrial solid wastes are brought together at these transfer sites and then transported to Cedar Hills Landfill. At the landfill, these wastes are buried in areas with special linings and are covered daily with a layer of soil. Rainwater percolating through the landfill is intercepted by a network of underdrains. Since the water can pick up chemicals and other substances from the decomposing waste, it (called leachate) is treated either on-site or at sewage treatment plants before eventual release into the environment. The rural ft landfills that do not have liners will have liners installed in new sections or will be closed to further disposal. aw SECTION 2 BACKGROUND INFORMATION 2-10 M i to , o1st Ar NE Transfer Station O Skykomish , Drop Boz � �•'oHoaghtor~.(;Transfer �Slation � North Transfer Stationo_►❑Carnation Landfill .• ,. �'�l !;►.ter -',�'. iactoria Transf,atian .� •[` •• �wirk,.. �B. 4r+f South Transfer Station'!A"�� RentonTransfe�` rtara -r� Cedar Hills landfill 'h Cedar alls Vasho landfill :'i3:oi'ak a landfill Hobart .. i�rafts.fefR n .. ❑ Landfill � =1 &iAlgona Transfer Station NScale Enumclaw � 0 5 Miles landfill Transfer Station ❑ Landfill O Rural Drop Boz Figure 2-3. MUNICIPAL SOLID WASTE FACILITIES 7 r a SECTION 2 Wastewater Facilities Municipal Sewerage Systems 1 t f BACKGROUND INFORMATION 2-11 Both King County and the City of Seattle are implementing other management options for the region's solid waste, including greatly increased recycling, and considering exporting wastes to facilities outside King County. Liquid wastes (sewage and other wastewaters) from homes and businesses are treated on-site in septic tank/drain field systems or are collected and treated in municipal wastewater treatment plants. Figure 2-4 shows the location of the regional Metro and local district sewerage systems in King County, and the areas where septic tanks predominate. Metro is the regional agency responsible for the collection and treatment of sewage and industrial and commercial wastewaters for much of the Seattle -King County area. Metro operates five treatment plants in a system covering much of the metropolitan area (including part of south Snohomish County). Thirty-nine sewerage agencies in King and Snohomish Counties contribute sewage to Metro's large collector lines which flow to Metro's treatment plants. These plants treat about 180 million gallons of wastewater per day. Nine separate districts or cities in the county collect and treat wastewater as well, accounting for about 20 million gallons per day. In addition to Metro, the sewer districts are: Southwest Suburban, Midway (Des Moines), Federal Way Water and Sewer, Vashon, Enumclaw, Black Diamond, North Bend, Sno- qualmie and Duvall. These each operate one or, more small wastewater treatment plants, all of which primarily treat resi- dential sewage, but contain small business wastewater as well. Treatment consists of primary (gravity settling) and, in some plants, secondary (biological breakdown) stages; remaining liquids are treated to kill any remaining pathogens before discharge to Puget Sound or rural rivers, while solids removed in the treatment processes (called sludge) are digested, then composted or used for soil enhancement. All of the primary treatment plants that discharge to Puget Sound are being upgraded to include secondary processes. SECTION 2 BACKGROUND INFORMATION 2 �-12 Metro - Richmond Beach Metro - Carkeek Park Metro West Point Metro - Alki SW Suburban v.) Salmon Crook Vashon N R SW Suburban - Miller Crook Des Moines Federal Way W&S- Redondo Federal Way W&S Lakota Scale N 5 Miles +.C3 Treatment Plant and Outfall 4 =Enumclaw High Percent Septic Tanks Figure 2-4. MUNICIPAL WASTEWATER TREATMENT FACILITIES .A W SECTION 2 BACKGROUND INFORMATION 2-13 Septic Tanks A septic tank and drain field, or "on-site" sewage treatment system, is an alternative disposal system for wastewater from households and small businesses generally used in less developed areas. The septic tank collects and holds the waste- water, allowing heavy suspended materials to sink to the bot- tom to be decomposed by bacteria. The wastewater then flows from the tank to the drain field. The drain field is a large area of soil that acts like a filter removing remaining sus- pended substances and some pollutants and bacteria. In King County, 16 percent of single family housing units are on septic tanks -- approximately 55,000 units (Land Develop- ment Information System, 1986). King County's 1986 Annual Growth Report estimates that 40 percent of new construction in the unincorporated county is not sewered and 1,000 to 2,000 .. new septic system units will be added each year (King County, 1986). Approximately 14 million gallons per day of waste- water were estimated to be discharged to septic tank systems .. in the county in 1977 (Metro, 1977). Septage is the liquid and sludge that accumulates in a septic ,w tank. Septage removal should occur every 4 to 6 years. In the Seattle -King County area, septage is taken to Metro's Renton Treatment Plant for secondary wastewater treatment. MW Storm Drains Almost all storm drains in the Seattle -King County region are separate from the sanitary sewers. The stormwater runoff from streets and parking lots is discharged directly into the nearest `o stream, river, lake or bay. In some older parts of Seattle, storm drains are connected to the sanitary sewer. When it rains in these areas, stormwater and untreated sewage can over- "' flow into receiving waters. Combined sewers are being phased out. Essentially, throughout the region, whatever goes down a catch basin or storm drain goes untreated into local waters. WM DESCRIPTION OF HAZARDOUS WASTE This section describes HHW and SQG wastes, provides projections of tonnage generated over the life of the plan and .. describes current hazardous waste management practices. .K M SECTION 2 BACKGROUND INFORMATION Household Hazardous Waste 2-14 Household hazardous wastes are those old or unwanted products that exhibit any of the characteristics of hazardous waste. They may be toxic, corrosive, ignitable or reactive, but they are exempt from federal and state regulation because of their household origin. Table 1-1 provides a general list of HHW categories. Specific HHW may be targeted for special management strategies because of the quantity of waste, type of hazard, degree of hazard, or public demand for services. A breakdown of types or categories of HHW is shown in Figure 2-5. Paints and solvents, motor oil, pesticides, and batteries were identified as targeted wastes in the planning area. Solvents are organic chemicals and are found in products used for: auto, boat, and equipment maintenance; cleaning agents; home repair and remodeling; and hobby and recreation sup- plies. Products with high concentrations of organic solvents include: oil-based paints, thinners, degreasers, spot removers, strippers, and cleaners. These products are targeted because they contain specific problem chemicals such as benzene, methylene chloride, toluene, trichloroethane, trichloroethylene, and tetrachloroethylene. Since these light -weight organic compounds do not normally bind onto soil or other particles, they have the potential to percolate through a landfill and end up in the leachate. They may concentrate to hazardous levels in sewer lines, pass untreated into the air at sewage treatment plants or pass straight through septic tanks and drain fields into the groundwater. Paints are a high volume waste that may contain hazardous constituents, including the solvent in oil-based paints, pigments such as lead and chromium, and additives such as mercuric fungicides (Morley and Associates, 1987). Used motor oil is insoluble, persistent, and may contain toxic chemicals and heavy metals. In addition to being potentially hazardous, oil is also a physical nuisance at transfer stations and landfills. All pesticides are designed to be toxic to one or more forms of life. Many will persist in the environment for a long time, affecting plant and animal life. Because of their persistence in ar .r 1 1 1 1 1 1 of jo so e SECTION 2 BACKGROUND INFORMATION 2-15 Pesticides (9.0%) Aerosols Corrosives (S.On 5olvents (4.0%) Otter (3.0%) caste Oil (8.0%) oil-Basea Palilt (31.0%) Corrosives Solvents ,41.0% atex Paint (35.0X) Household Hazardous Wastes Other (9.0X) Latex Paint (Y. OX) Paste Oil (42 CX) uii m int i6.U%) SQG Hazardous Wastes Figure 2-5. BREAKDOWN OF HHW AND SQG WASTES BY TYPE HHW breakdown is based on experience at area collection day events. SQG breakdown is from SCS Engineers, 1984. t SECTION 2 BACKGROUND INFORMATION 2-16 1 the environment, pesticides such as DDT, aldrin and dieldrin have been banned. Others, such as the organo -phosphate pesti- cides, break down in the environment in a relatively short period of time, but are initially highly toxic and constitute a health risk. Unwanted pesticides must be handled very care- fully to protect health and the environment. Household and automobile batteries contain lead, silver oxide, mercury, lithium, cadmium, or other heavy metal compounds that can cause leachate contamination and create ash toxicity problems in solid waste incineration. Automobile batteries also contain corrosive acids that create safety hazards at landfills and transfer stations. Small Quantity Generator Hazardous Waste .• Businesses that generate hazardous wastes have been regulated through the federal Resource Conservation and Recovery Act, the federal Clean Water Act and the Washington State Hazard- ous Waste Management Act for over a decade. However, any business that generates less than 220 lb/month of hazardous waste is conditionally exempt from state and federal hazardous waste regulations. Such businesses are termed "Small Quantity Generators" or SQGs. They are exempt from some of the paperwork associated with the regulations, but still must use proper waste management procedures, or they can be subject to fines and possible criminal prosecution. An SQG may be either a small or large business. The typical profile of an SQG is a business that: • employs fifty or fewer people (in Washington, more than ninety percent of all businesses fall into this category); and • produces quantities of hazardous waste that would take more than two months to fill a fifty-five gallon drum. Table 1-2 provides a general list of SQG waste categories and examples of most likely types of businesses that are SQGs. Because of the diversity of businesses that generate small quantities of hazardous waste, and the wide variety of sub- stances used, characterizing SQG wastes is a difficult task. M IN WA SECTION 2 BACKGROUND INFORMATION 2-17 Waste characterization activities have been undertaken locally and elsewhere around the country. The most common types of wastes found have been lubricating oil, non -halogenated solvents, paint and paint sludges, acids and caustics, and halogenated solvents such as tetrachloroethylene, and pesticides. A study in California for North Hollywood, for example, found that 83 percent of SQG waste was waste oils and solvents (SCS Engineers, 1984). •• Both Metro and the Seattle -King County Department of Public Health have continuing programs attempting to determine more specifically which businesses are disposing of which wastes. .. Audits of businesses in three areas in King County enabled the Health Department to identify certain businesses likely to generate small amounts of hazardous wastes (see Table 2-4). .. Metro has also developed a list of industries that are likely to discharge contaminants to the. sewer system. These industries are listed in Table 2-5. Additional details regarding hazardous waste types, quantities, and management by small businesses are provided in Section 4.3 of the Issue Paper (Appendix Q. Projections of HHW and SQG Waste 1989-2009 The total of HHW and SQG hazardous waste is estimated to be one percent of the solid waste stream based on data from solid waste sorts and surveys (see Appendix Q. Best available data indicate that HHW represents about one-third of the hazardous waste in the solid and liquid waste streams by weight (Appendix B). The remaining two-thirds of the hazard- ous waste comes from SQGs. It is estimated that approxi- mately 85 percent of this hazardous waste by weight is disposed of in the municipal solid waste and 15 percent in the liquid waste stream (Figure 2-6). .r Projected tonnage of HEW generation over the life of the plan (assuming no waste reduction programs are implemented) ap- ■• pears in Table 2-6. The projected tonnage of SQG waste generation over the life of the Plan (assuming current genera- tion rates stay constant) appears in Table 2-7. These projec- rw tions provide the basis for reduction and diversion goals in the plan. Figure 2-7 graphically describes these projections. on M s SECTION 2 BACKGROUND INFORMATION 2-18 ME we Food and Kindred Products Chemical and Allied Products Primary Metal Industries Machinery, except Electrical Table 2-4. BUSINESS GROUPS SURVEYED IN KING, PIERCE AND THURSTON Water Transportation Air Transportation COUNTIES Personal Services Business Services Motion Pictures Miscellaneous Services ow Pesticide Users Pesticide Applications Services Petroleum Refining and Related Industries Metal Manufacturing Equipment Repair r Chemical Manufacturing Construction Electrical and Electrical Machinery, Equipment and Supplies Wood Preserving Motor Freight Terminals Formulators Furniture/Wood Manufacture and Refinish Miscellaneous Manufacturing Industries Laundries Cleaning Agents and Cosmetic Manufacture *0 Other Services Paper Industry Automotive Dealers and Gasoline Service Stations Photography Educational and Vocational Shops Textile Manufacturing Wholesale and Retail Sales no Vehicle Manufacturing Printing/Ceramics 'Baroga, et. al., 1986 im .r► Table 2-5. "HIGH PROBABILITY" DISCHARGERS OF CONTAMINANTS BY INDUSTRY TYPE' Food and Kindred Products Chemical and Allied Products Primary Metal Industries Machinery, except Electrical aw Transportation Equipment Railroad Transportation Water Transportation Air Transportation Personal Services Business Services Motion Pictures Miscellaneous Services Ml Printing, Publishing and Allied Industries Petroleum Refining and Related Industries Stone, Clay, Glass, and Concrete Products Fabricated Metal Products, except Machinery and Transportation Equipment Electrical and Electrical Machinery, Equipment and Supplies Measuring, Analyzing and Controlling Instruments Photographic, Medical and Optical Goods, Watches, and Clocks 4jw Miscellaneous Manufacturing Industries Motor Freight Transportation and Warehousing Electric, Gas and Sanitary Services wr Automotive Dealers and Gasoline Service Stations Automotive Repair, Services and Garages Miscellaneous Repair Services 'Based on an analysis of Standard Industrial Classification (SIC) Codes by Metro Industrial Waste Section, 1987 T rs W SECTION 2 BACKGROUND INFORMATION 2-19 1/3 from House r va r-- 2/3 from SOG Sources Figure 2-6. CONTRIBUTION OF HHW AND SQG WASTE TO MUNICIPAL WASTE STREAMS 9W 85 percent of total Household and Small Quantity Generator hazardous waste isfound in the solid waste stream. The remaining 15 percent is found in the liquid waste aw stream and the environment. Of this, one-third of the waste comes from household sources and two-thirds from SQGs. an am SECTION 2 BACKGROUND INFORMATION 2-20 Table 2-6. HOUSEHOLD HAZARDOUS WASTE TONNAGE PROJECTIONS' 'Amounts reported in tons. Table 2-7. SMALL QUANTITY GENERATOR HAZARDOUS WASTE TONNAGE PROJECTIONS' 1989 1994 1999 2009 Total Tonnage of Hazardous Waste 19,000 22,000 25,000 33,000 Total HHW Generated 6,300 7,200 8,300 11,000 HHW in Solid Waste 5,400 6,100 7,000 9,400 HHW in Wastewater 950 1,100 1,200 1,700 'Amounts reported in tons. Table 2-7. SMALL QUANTITY GENERATOR HAZARDOUS WASTE TONNAGE PROJECTIONS' 'Amounts reported in tons. 1989 1994 1999 2009 Total Tonnage of Hazardous Waste 19,000 22,000 25,000 33,000 Total SQG Hazardous Waste Generated 12,700 14,700 16,700 22,000 SQG Waste in Solid Waste 10,800 12,500 14,200 18,700 SQG Waste in Wastewater 1,900 2,200 2,500 3,300 'Amounts reported in tons. SECTION 2 BACKGROUND INFORMATION 2-21 24000 22000 20000 18000 16000 T O N S 14000 12000 10000 8000 6000 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 YEARS •• HHW O• SOG Figure 2-7. HAZARDOUS WASTE TONNAGE PROJECTIONS FOR 1990-2009 SECTION 2 BACKGROUND INFORMATION 2-22 CURRENT DISPOSAL OF HAZARDOUS WASTE HHW and SQG wastes are currently handled in a variety of ways. Householders store hazardous products in the garage, dispose of them in the garbage or take them to transfer stations and landfills, dump them down the sink or storm drains or directly onto the ground. A public opinion survey conducted as part of this planning process found that many �. — householders routinely dispose of HHW in the garbage can or down the drain (Appendix D). Some results of the survey are shown in Figures 2-8 through 2-11. The most common avenues of disposal used by the SQGs are landfilling or discharge into available sewers. These two disposal methods account for approximately 60 to 80 percent of the SQG waste generated, according to reports from other states. Other more acceptable disposal practices such as recycling, reuse, on-site treatment, and shipment to a licensed TSD facility are being used by a comparatively small number of SQGs. Surveys of disposal practices of businesses in the region have provided some idea of the proportion of hazardous wastes disposed of in an environmentally unsound manner. These results are summarized in Tables 2-8 and 2-9. In recent years, some programs and facilities to deal with HHW wastes have become available. Programs such as HHW collection days, HHW permanent collection facilities and recycling opportunities are available to some degree for HHW disposal and treatment. However, these programs can handle only a small percentage of the waste generated. Local collec- tion day events, for example, provide a disposal option for only about two percent of the population. The rest of this section describes in more detail current disposal practices and their effect on the solid and liquid waste streams and the environment. Long-term Storage Household Hazardous Waste In a local residential opinion survey of the household hazardous waste issue, it was determined that approximately 90 percent of the surveyed population have hazardous products in so it 7-1 .r IN .r 1W M 0i r too 90 so 70 60 90 g 40 ]0 ]0 in 0 GARBAGE LAWILL 3IIL rmRz Dtln Figure 2-8. DISPOSAL METHODS FOR HOUSEHOLD CLEANERS 100 90 GO 70 � 60 SO S n 40 30 20 10 0 6AREA69 LAI BY ILL OIORE WIN Figure 2-9. DISPOSAL METHODS FOR PESTICIDES/HERBICIDES too 90 GO 70 W 90 g ai GO J0 90 10 0 GARBAGE LAvorILL BTORE 01=1 DE/RR Figure 2-10. DISPOSAL METHODS FOR PAINTS/SOLVENTS 100 90 so 70 r AO ]0 g of GO b 20 LO 0 GARBAGE BORT LANDFILL BTORL OTIER EVER Figure 2-11. DISPOSAL METHODS FOR AUTOMOBILE PRODUCTS N DK/NR = Don't Know/No Response N W SECTION 2 BACKGROUND INFORMATION 2-24 Table 2-8. SQG HAZARDOUS WASTE GENERATION AND DISPOSAL FOR KING, PIERCE, AND THURSTON COUNTIES' Gal/Month Gal/Month Hazardous Hazardous Wastes Total Businesses Waste Improperly Group Name Businesses Surveyed Generated Disposed Pesticide Users 29 23 33 9 Pesticide Application 145 63 27 2 Chemical Manufacturing 26 8 0 0 Wood Preserving 13 7 205 36 Formulators 13 6 0 0 Laundries & Dry Cleaners' 392 52 1133 1100 Other Services 167 56 224 196 Photography 462 59 145 14 Textile Manufacturing 13 8 4 3 Vehicle Maintenance 3241 70 533 53 Equipment Repair 118 58 46 3 Metal Manufacturing 1238 61 212 31 Construction 1342 64 53 4 Motor Freight Terminals 6 2 0 0 Furniture/Wood Manufacturing 250 58 64 23 and Refinishing Printing/Ceramics 831 55 219 64 Cleaning Agents and Cosmetics 17 9 0 0 Manufacturing Other Manufacturing ill 45 15 0 Paper Industry 15 6 0 0 Education and Vocational 160 27 33 0 Shops Wholesale and Retail Shops 169 48 0 0 Laboratories NOT SURVEYED 'Baroga et al., 1986 'Wastes given in pounds rather than gallons. w I" SECTION 2 BACKGROUND INFORMATION 2-25 M I Table 2-9. SQG HAZARDOUS WASTE MANAGEMENT PRACTICES FOR SOUTH PARK AND N.W. KENT AREAS' Gal/Month Gal/Month Hazardous Hazardous Wastes Businesses Wastes Disposed of Group Name Surveyed Generated Improperly Pesticide Application 21 202 2 Chemical Manufacturing 0 0 0 Wood Preserving 0 0 0 Formulators 3 27 2 Laundries & Dry Cleaners' 52 3449 15893 Other Services 4 1 1 Photography 1 300 0 Textile Manufacturing 1 1 0 Vehicle Maintenance 8 963 1554 Equipment Repair 3 691 3205 Metal Manufacturing 17 3371 17 Construction 5 233 20 Motor Freight Terminals 1 95 0 Furniture/Wood Manufacturing 1 60 0 and Refinishing Printing/Ceramics 8 219 3 Cleaning Agents and Cosmetics 1 5 0 Manufacturing Other Manufacturing 2 0 0 Paper Industry 0 0 0 Education and Vocational 0 0 0 Shops Wholesale and Retail Shops 29 255 0 Laboratories NOT SURVEYED 'Yerkes et al., 1988 'Pounds rather than gallons 'Tetrachloroethylene ("perc") contaminated waste disposed of in dumpsters 'Oily steam cleaning waste disposed of in storm sewers (no oil/water separator present) 5100 gallons of oily, steam cleaning waste disposed of in storm sewers (no oil/water separator present), 220 gallons of non -halogenated solvents, a regulated amount, stored beyond the allowable deadline. M I SECTION 2 BACKGROUND INFORMATION 2-26 / the home (Appendix D). In addition, approximately ten per- cent of the surveyed population store their hazardous waste in 0 the house or garage instead of disposing of it. The stored ❑ amounts also represent accumulated HHW brought to collection events held in the Seattle -King County area in the past few P1; years. A 1982 Metro study estimated that over 100,000 At" pounds of banned pesticides, such as DDT and 2,4,5-T, were still stored in King County households (Metro, 1982). Small Quantity Generators SQGs are often unaware of appropriate disposal options for their hazardous wastes. In such cases, wastes may accumulate over a period of months. This practice puts SQGs at risk for enforcement actions when accumulation exceeds the thresholds that designate regulated generators. Long-term storage of hazardous chemicals can also lead to property damage and site contamination. As real estate, financial and insurance institu- tions become more aware of the financial risks associated with contaminated properties, these properties can become substan- tial liabilities for business owners. Solid Waste Stream Nationwide surveys and local solid waste surveys and sorts have reported values for the hazardous waste fraction of muni- cipal solid waste ranging from less than 0.1 percent to over 1.0 percent by weight. For the purposes of the plan, a value of it i I 'I jl 1.0 percent is assumed. Surveys specifically targeted at HHW I II I i have reported values in the 0.3 to 0.4 percent range. The best i available data indicate that HHW represents about one-third of I the hazardous waste found in King County's solid waste Lstream, or about 0.33 percent of the total solid waste stream. Based on this assumption, the HEW load in the County's solid waste is estimated at about 5,400 tons for 1990, about 4 pounds per person per year. The remaining two-thirds, or 0.66 percent of the total solid waste stream comes from SQGs. The load of SQG wastes for 1990 is 10,800 tons. Household Hazardous Waste Waste composition studies show that waste paints, used motor oils, batteries, cleaners, and solvents are the largest and most common components of HHW found in municipal garbage. E t No M em e A ow W SECTION 2 BACKGROUND INFORMATION 2-27 W w. M Two years ago, almost 100 percent of dry cleaner wastes were placed into dumpsters and disposed of in the solid waste stream. Currently, over 50 percent of the wastes are being collected by authorized recycling firms. 1988 Health Depart- ment audits indicate that 56 percent of the dry cleaner wastes are being managed properly (Yerkes, et al., 1988). Improved management practices are a result of an intensive education and technical assistance effort by the Dry Cleaners Association. Liquid Waste Stream The liquid waste stream is 99.9 percent water by weight. However, small quantities of hazardous wastes in the liquid waste stream can significantly compromise the wastewater treatment process or water quality, even in concentrations of only a few parts per billion. Certain hazardous chemicals, including heavy metals and toxic organic compounds, are frequently detected in the liquid waste stream. The best available data indicate that 307 tons per year of actual hazardous chemicals are found in Metro's sewerage sys- tem. This is the amount of pure copper, zinc, benzene and other hazardous chemicals found through chemical analysis of A local study found that much of the HHW in the solid waste stream is stored and periodically disposed of by drop-off at a solid waste transfer station (Cal Recovery Systems, 1985). Forty percent of the HHW in solid waste showed up in resi- dential pick-up. Sixty percent is brought to transfer stations by "self -haulers," often after long-term storage. Self -haulers were identified in the Issue Paper as significant contributors of HHW to solid waste to be specifically addressed in the plan. Small Quantity Generator Hazardous Waste A 1986 survey of SQGs in King, Pierce and Thurston counties identified the dry cleaning industry as a significant contributor of halogenated solvents to local landfills (Baroga, et al., 1986). The primary solvent used in the dry cleaning process is tetra- chloroethylene (also known as perchloroethylene or "perc"), .. which is listed by Ecology as a hazardous waste. Ecology does not allow disposal of perc in municipal landfills (WAC 173-303). W w. M Two years ago, almost 100 percent of dry cleaner wastes were placed into dumpsters and disposed of in the solid waste stream. Currently, over 50 percent of the wastes are being collected by authorized recycling firms. 1988 Health Depart- ment audits indicate that 56 percent of the dry cleaner wastes are being managed properly (Yerkes, et al., 1988). Improved management practices are a result of an intensive education and technical assistance effort by the Dry Cleaners Association. Liquid Waste Stream The liquid waste stream is 99.9 percent water by weight. However, small quantities of hazardous wastes in the liquid waste stream can significantly compromise the wastewater treatment process or water quality, even in concentrations of only a few parts per billion. Certain hazardous chemicals, including heavy metals and toxic organic compounds, are frequently detected in the liquid waste stream. The best available data indicate that 307 tons per year of actual hazardous chemicals are found in Metro's sewerage sys- tem. This is the amount of pure copper, zinc, benzene and other hazardous chemicals found through chemical analysis of SECTION 2 Household Hazardous Waste Small Quantity Generator Hazardous Waste BACKGROUND INFORMATION 2-28 the wastewater. A rough translation of these data into compar- able figures for total product tonnage that contains these hazardous chemicals, which is the form the solid waste infor- mation is in, indicates that 2,850 tons per year (in 1989) of the products containing hazardous chemicals are disposed of down the drain. This amounts to about 15 percent of the total hazardous waste in both the solid and liquid waste streams (Appendix C). HHW represents roughly one-third of this total. Therefore, the amount of HHW put into local wastewaters is estimated to be 950 tons per year. This relatively small amount in comparison with the solid waste estimates is supported by the public opinion survey, which found that a very small percentage of the HHW was acknowledged to be dumped down the drain. The other two-thirds, or about 1,900 tons per year, comes from commercial or industrial sources. Hazardous wastes enter the liquid waste stream from daily events in and around the home. Chemicals are washed down the drain during routine cleaning, washing, and food prepara- tion. The kitchen, bathroom, and utility sinks may also receive quantities of products that are no longer used or wanted. Although each incident may involve a small amount of material -- a cup or a pint -- the total load of these materials in the wastewater system is significant. Table 2-10 shows the results of a 1984 Metro study on the residential contribution of toxic heavy metals to the sewer system. Estimates of the wastewater attributable to all commercial or industrial sources range from five to fifteen percent of total wastewater volume. The results of recent surveys conducted by Metro and the Health Department indicate the major contributors of hazardous waste to the sewer system are companies using solvents in their operations. Solvents that have been consistently detected in Metro wastewaters and are associated with SQG industries include: Methylene chloride, 1,1,1 -trichloroethane, toluene, trichloroethylene, perchloroethylene, acetone, phenol, benzyl alcohol and dichlorobenzene. E w M 0 gr as SECTION 2 M on M r r, M BACKGROUND INFORMATION 2-29 Table 2-10. RESIDENTIAL CONTRIBUTION OF COMMONLY DETECTED METALS TO SEATTLE METRO'S WASTEWATER TREATMENT PLANTS Residential Load' Renton West Point Compound Treatment Plant Treatment Plant Uses and Products lb/day percent lb/day percent Antimony 0.17 37 1.3 22 Flame retardant, dyes, inks, fireworks, matches Arsenic 0.62 36 1.2 30 Fungicides, wood preservatives Cadmium 0.71 26 1.3 17 Paint pigments, cigarettes, PVC plastics, dyes, shampoos, pesticides Chromium 0.76 2.5 3.1 2.4 Powder laundry soap, bath soap, dyes, shampoos, pesticides Copper 25.0 36 50.0 26 Powder laundry soap, shampoos, kitchen cleaners Lead 14.0 34 40.0 23 Paint products, cosmetics Mercury 0.13 53 0.27 41 Paint pigments, thermometers, photographic products, cosmetics Nickel 10.0 51 28.0 40 Bath soap, powder laundry soap, r Silver 0.40 9 1.1 8 Zinc 35.0 41 150.0 41 ft M powder bleach, kitchen cleaners, dishwasher detergent, dyes, shampoos Batteries, pesticides, photographic products Bath soap, powder kitchen cleaners, deodorant, pesticides, shampoos, cosmetics, polish 'Data are in pounds per day and percentage of the total mass loading into each plant. Loadings are calculated from data presented in Cooley et al., 1984. SECTION 2 Septic Tanks BACKGROUND INFORMATION 2-30 Solvents are not removed by primary treatment, which is only a settling process. About 70 percent of the solvents are removed by the secondary treatment process, but they are "removed" by their transfer into the atmosphere rather than breaking down the actual chemical compounds. These volatile organic compounds are more likely to be broken down in the atmosphere, by photo -oxidation, then if they were to remain in sewage. However, atmospheric releases can contribute to local air pollution. The remaining 30 percent is discharged with the liquid effluent into the environment (Hasselman, et al., 1984). Septic tank systems, even more so than municipal sewerage systems, are not designed to handle hazardous chemicals. Contaminants pass through the systems largely untreated, percolate through the drain field and migrate to groundwater. Many households in the densely populated suburban cities in King County use groundwater for drinking water supplies. Approximately two-thirds of the county's area relies solely on groundwater, including all of Issaquah, Federal Way, Enum- claw, parts of Redmond, Renton, and Carnation and much of the unincorporated county (Rolla, personal communication, 1988). Any groundwater contamination from disposal of HHW or SQG wastes in septic tanks in these areas, therefore, can have immediate serious consequences for drinking water. Of particular concern are the volatile organic compounds -- a class of chemicals commonly found in household and SQG solvents and septic tank cleaning solutions. These compounds do not readily degrade in the underground environment, do not attach to soil particles and are, therefore, highly mobile. A Tacoma study discovered dichloromethane and toluene in contaminated groundwater samples (DeWalle and Schaff, 1980). These are chemicals found in products such as paint thinners, toilet -bowl cleaners, solvents and degreasers. The most frequently found organic contaminant in groundwater nationwide is trichloroethylene, an industrial solvent, degreaser and septic tank cleaner. Trichloroethylene is also found in products such as cleaning fluids, engine and metal degreasers, spot removers, and floor strippers (Hathaway, 1980). Metals from domestic on-site systems have also been found to be responsible for contamination of groundwater supplies. 40 .r r- M M M i1 7 1 I SECTION 2 BACKGROUND INFORMATION 2-31 1 Septage pumped from septic tanks in King County is trucked to the Renton Treatment Plant and so is a source of some hazardous chemicals from households and small businesses into the municipal system. i Storm Drains Storm drainage systems are another avenue for HHW and SQG wastes entering the environment. Almost all storm drains in the Seattle -King County region are separate from the sanitary sewers and discharge directly into the nearest stream, river, ' lake, or bay. Household wastes most commonly dumped down storm drains include used motor oil, antifreeze, gasoline, car wash water, concrete rinse, acid masonry washes, paint rinse and pesticides. Many small businesses have storm drain con- nections from their sumps or operational areas, allowing oils, greases, solvents and other chemicals to wash directly into the storm drain system. Many fish kills that have occurred in recent years in King County's urban streams appear to be the result of direct dumping of a hazardous substance. Spills may occur outdoors where hazardous substances are washed directly into the environment to enter surface and groundwaters. Stormwater runoff picks up hazardous materials that have been spilled or dumped outside. Local stormwater runoff studies have found most of the heavy metals in storm - water as well as organic chemicals such as oil and grease, benzene, ethyl benzene and toluene, and some pesticides such as DDT, lindane and pentachlorophenol (Galvin and Moore, 1982). Many of these contaminants are or have been ingredients in household or commercial products. EXISTING PROGRAMS FOR MANAGING HAZARDOUS WASTE Information and Education Several existing programs provide information to households and businesses on good hazardous waste management practices, although they are limited in nature. The Health Department operates the Hazards Line, a phone line which offers infor- mation on HEW recycling or disposal. This service, staffed SECTION 2 TgMrard�.`�` 0dless r��r er.r r r�r r SN � `��� . V d BACKGROUND INFORMATION 2-32 by one FTE', receives an average of 50-60 calls per day. In addition, Ecology sponsors the statewide "Hazardous Substance Information Hotline," that answers questions about hazardous substances in general. Ecology also sponsors a "Recycle Hotline" that provides information on local recycling options, including those for waste oil and batteries. Public and private agencies have prepared general and targeted educational materials such as brochures, newsletters, mailings and media spots on HHW. Ecology's Hazardous Substances Information and Education Office acts as a clearinghouse for many educational materials. The Educational Subcommittee of the Hazardous Waste Interagency Coordinating Committee has completed a bibliography of various audio/visual and printed information on HHW (Bennett, et al., 1988). Both private and public agencies have educational materials specifically targeting SQGs. Several trade associations have made efforts to inform their members of regulations concerning proper waste disposal. Ecology and Metro offered workshops and seminars, and additional state -funded workshops are being offered by organizations such as the Waste Information Network. The Intergovernmental Resource Center in Vancou- ver, Washington has a two-year grant to run a technical re- source center for SQGs. This state -funded program provides SQGs with access to technical publications on waste reduction and disposal. The telephone information line begun by the In- tergovernmental Resource Center has been moved to Ecology. Collection and Disposal Household Hazardous Waste Disposal services for HHW have mainly taken the form of collection events or 'Round -Ups". However some existing programs provide more continuous service. During a collection event, residents bring their HEW to a designated location. Trained personnel accept and package the wastes for reprocessing and disposal at licensed hazardous 'FTE = 'Tull -time Equivalent," or staffing at an annual full-time budgeted position level. FTE can refer to both full and part time staff. so 0 0 ■i e SECTION 2 rr 1 r o. BACKGROUND INFORMATION 2-33 waste facilities. In King County, four regional collection events have been held in the last three years, and other collection days have been sponsored by suburban cities. Over 700 tons of HHW have been collected in these programs. To provide more continuous service, the City of Seattle opened a HHW collection facility at the Solid Waste Utility's South Transfer Station in October, 1988. The facility is open four days a week including weekends. All commonly generated types of HHW are accepted. Seattle is planning to open a second facility in 1990 and King County will provide a mobile collection unit that moves from site to site for set periods of time, starting in late 1989. The Health Department accepts banned and restricted -use pesticides, wood preservatives, and non -leaking fluorescent light ballasts that contain PCBs at drop-off facilities located at all Health Department locations. At the request of the City of Bellevue, Eastside Disposal Service is offering a limited collection service for HHW for a six-month trial period starting in April, 1989. This service consists of a bi-monthly weekend drop off similar to a round- up, and is only open to Bellevue residents. The Port of Seattle provides collection facilities for hazardous waste for its tenants at Shilshole Marina and Fishermans Terminal. As a public service, one TSD company in Seattle accepts HHW for free at limited times and in limited quantities from the general public. Another TSD also accepts HHW; however, there is a $10 minimum charge for this service. Most of the wastes collected by these programs are disposed of as regulated hazardous wastes, either in hazardous waste landfills or incinerated in hazardous waste incinerators in accordance with state and federal regulations. Some wastes can be recycled, for example used oil and batteries. Used motor oil is easily recyclable; however, because of the fluctuating dollar value of used motor oil, there is limited economic incentive for gas stations to collect and recycle it (Morley and Associates, 1987). The City of Seattle has estab- lished used oil recycling locations at its two transfer stations to SECTION 2 AS?- Mpj. �v wCOLN m i is Small Quantity Generator Hazardous Waste BACKGROUND INFORMATION 2-34 help reduce the quantity of this hazardous waste in the solid waste stream. In 1989, King County will provide oil recycling facilities at its transfer stations and landfills as well. Several companies in the King County area provide recycling services for used or contaminated motor oil: Crosby & Overton, Kent; Chemical Processors, Seattle; New Age Recycling, Tacoma; Northwest EnviroServices, Seattle; East Marginal Recycling, Seattle; Petroleum Reclaiming Service, Seattle; Resource Recycling, Kirkland; Tacoma Recycling, Tacoma; and Merit Oil, Seattle (Appendix C). Automobile and household batteries can also be recycled. Most lead acid batteries collected locally are sent to lead smelters in Taiwan and overseas. Standard Batteries and Budget Batteries accept used lead acid batteries for recycling. Some retailers and service stations accept used batteries in exchange for new batteries at the time of purchase. ESHB 1671, adopted by the 1989 Washington State Legislature re- quires that all vehicle battery sales outlets accept and recycle used vehicle batteries. The Speyer Company in Seattle accepts mercury and mercury batteries for recycling. The City of Seattle Solid Waste Utility is investigating paint recycling options including reprocessing waste latex paint and materials recovery of solvent -based paint. AGCO Metaleck of Lynnwood, CMX of Seattle, Hallmark Metals of Mount Vernon, LMD Silver Resources of Puyallup, and Pacific X -Ray of Seattle accept photographic chemicals containing silver for recycling. Private facilities that handle regulated hazardous wastes are also available to small quantity generators. These private companies include waste brokers, recyclers, reclaimers and clean-up contractors, in addition to licensed treatment, storage and disposal (TSD) facilities. Hazardous waste "brokers" offer collection service to SQGs, including consultation about regulations, identification of hazardous wastes, and transport of hazardous wastes to TSD facilities. In King County, several TSD facilities will handle SQG waste. However, these facilities require hazardous waste .M rr 1W M SECTION 2 BACKGROUND INFORMATION Ow profiles (laboratory tests to classify the wastes) before accepting wastes for treatment or disposal. These tests are often very expensive for the small volumes of wastes brought in by the SQGs. For this reason, many SQGs choose not to use the TSD services. A number of SQG collection day events have been held in Washington State. These programs are usually sponsored by local governments and run by a TSD facility. Chempro also offer an SQG collection service once a month for a fee. All firms handling hazardous wastes must obtain permits from Ecology and must use the uniform hazardous waste manifest form to ship hazardous wastes off-site. These firms must also comply with state and federal regulations. r ROLES, REGULATIONS AND RESPONSIBILITIES Although HHW and SQG wastes are not specifically regulated at the federal level, state and local agencies have regulatory rr. roles for parts of the various waste streams. This section =— provides a brief overview of the roles, responsibilities and regulations of agencies involved in management of HHW and 05 SQG wastes in King County (a more detailed discussion is 4 o. included in Appendix Q. Federal Environmental Protection Agency The Environmental Protection Agency is responsible for enforcement of environmental laws and regulations at the federal level. It is under the Resource Conservation and Recovery Act (RCRA) as implemented by EPA that hazardous wastes are defined and regulated. Household hazardous waste is exempted from regulation at the federal level. A number of other federal laws affect the management of hazardous waste including the Superfund Amendments and Reauthorization Act, and the Clean Water Act. W State of Washington Department of Ecology Within Washington State, EPA has delegated the authority to manage hazardous waste and implement RCRA to the Depart - M M �7 SECTION 2 BACKGROUND INFORMATION 2-36 ' ment of Ecology. Hazardous waste generated in Washington is regulated under the Hazardous Waste Management Act [RCW 70.105] as implemented by the Dangerous Waste Regulations [WAC 173-303]. Small quantities of hazardous waste are conditionally exempt, which means that such waste must still be managed appropriately. Under this act local governments are required to develop local hazardous waste management plans, which must be approved by Ecology. Ecology inspects facilities that use, handle, store, transport or generate hazardous waste. They also sponsor some information programs for .. hazardous waste generators. EPA has also delegated to Ecology the responsibility for .. issuing National Pollutant Discharge Elimination System (NPDES) permits. These permits are issued to all facilities that discharge wastewater directly into surface waters. Locally, all sewage treatment plants have NPDES permits. Permit con- ditions specify allowable effluent concentrations of certain priority pollutants, such as heavy metals. Seattle -King County Department of Public Health M The Health Department is responsible for enforcing state public health statutes, rules and regulations of the State Board of Health and of the Secretary of the Department of Social and Health Services, as well as all local health rules, regulations and ordinances. _. The Health Department has broad authority to enforce existing state hazardous waste requirements and to adopt additional regulations pertaining to hazardous waste as it affects the public health. The Department has authority to regulate solid waste including SQG waste and HHW in the solid waste stream. Specific prohibitions at present are: restricted use pesticides, wood treating preservatives and used motor oils. This regulation applies to all of King County except the City of Seattle. However, since most of Seattle's solid waste is r+ disposed of at Cedar Hills Landfill in King County, these prohibitions also apply to the city's waste stream. The Health Department also permits and inspects septic tanks upon installation and/or sale of property. The Health Department has the authority to inspect businesses that handle ..� hazardous materials. This authority allows Health Department N M M SECTION 2 BACKGROUND INFORMATION 2-37 staff to audit SQGs for both information gathering and compliance purposes. Local Solid Waste Agencies Local solid waste agencies operate transfer stations, landfills and garbage collection systems. These agencies are beginning to deal with the problems of HHW and SQG wastes in the solid waste stream. For example, the City of Seattle Solid Waste Utility is drafting an ordinance to ban HHW and SQG hazardous wastes from the solid waste stream. The Municipality of Metropolitan Seattle (Metro) ■r Metro is the regional agency responsible for the collection and treatment of industrial, commercial and residential wastewaters r• for much of the Seattle -King County area. Metro's boundaries include portions of south Snohomish County and exclude southwestern King County, Vashon Island and the Snoqualmie .. Valley. Thirty-nine sewerage agencies in King and Snohomish Counties contribute wastewater to Metro's large interceptor sewers which flow to Metro's five wastewater treatment plants. Metro issues permits and authorizations for sewer system users who discharge significant quantities of wastewater and/or hazardous contaminants. As a condition of obtaining a waste discharge permit, the permit holder may be required to install pretreatment facilities, make plant or process alterations or monitor discharges. Metro also coordinates the Interagency Water Quality Trouble Call System. This system provides timely and directed responses to reported water quality problems. W Local Sewer Utilities/Districts All of the local sewer utilities have authority to prohibit discharge of hazardous chemicals to the sewer system. Some sewer utilities, including the City of Seattle Drainage and Wastewater Utility, also have authority to prohibit such r. discharges to storm drains. Such prohibitions are difficult to enforce, however. Some of the sewer districts that are not E-1 W 77 .0 SECTION 2 BACKGROUND INFORMATION 2-38 M components of Metro provide services similar to those of the large metropolitan agency. r Local Drainage Utilities Several local jurisdictions, including King County, Seattle, Bellevue, Kent, Auburn, and Redmond, have established drain- age water utilities responsible for controlling stormwater and urban runoff. This responsibility includes maintaining water quality of runoff. Local Fire and Building Departments PROBLEMS AND NEEDS Solid Waste Stream as Local fire and building departments, and the King County .. Building and Land Development Division (BALD) are respon- sible for enforcing the Uniform Fire Code which governs storage of hazardous materials above designated threshold .. amounts. The Code makes no distinctions between hazardous materials and hazardous wastes. Fire departments and BALD issue permits for storage of hazardous materials and .r► periodically inspect all businesses. From the discussions in the previous sections, a variety of problems in HHW and SQG waste management can be identi- fied, and these are discussed below. Other program needs for both householders and SQGs were identified during the public involvement process for the plan. These are also discussed in this section. M HHW and SQG waste disposed of in the solid waste stream may contribute to leachate contamination, resulting in degradation of leachate collection systems and failure to meet contaminant limits. Ecology has issued minimum functional standards for solid waste landfills (WAC 173-304), including a plastic liner 80 millimeters thick, a clay underliner, and a gas and leachate .. ftV e SECTION 2 BACKGROUND INFORMATION 2-39 M up collection system. At present, the King County landfill at Cedar Hills meets the state minimum functional standards. Re- quired safeguards are in place in the operating areas of the landfill. However, the removal of solvents and other hazardous constituents from the waste stream may enhance the long-term viability of the liners and reduce leachate contamination. Contaminants that could have come from consumer products and small businesses have been found in samples of leachate from the Cedar Hills and the now -closed Kent Highlands land- fills. Metro's Toxicant Pretreatment study detected phenol, phthalates, isophorone, methylene chloride, toluene, trichloro- ethylene, ethylbenzene, PCBs, DDE, aldrin, dieldrin, and endrin aldehyde in the leachate (Cooley, 1984). The rural landfills do not, at present, meet state standards. However, these are being upgraded or closed. Duvall has closed; Cedar Falls will close in 1989 and will be replaced with a drop box. The County is asking for waivers from the minimum functional standards for Enumclaw and Hobart land- fills, which are both scheduled for closure in the 1990s. There are no liners for these landfills, but they do have leachate collection systems (Monk, personal communication, 1988). The Vashon landfill has a liner. Leachate contaminant limits may be tightened in future. Cedar Hills is currently meeting the leachate contaminant limits set by Metro (Monk, personal communication, 1988). However, Metro regularly reviews these limits and state and federal ef- fluent standards continue to get stricter. The limits could well become more stringent. To meet the current limits, the leach- ate must be aerated, a form of treatment, before it is piped to Metro's Renton Treatment Plant. If the Cedar Hills permit limits are made more stringent, either by decreasing allowable concentrations of currently regulated pollutants or by adding new ones such as metals or toxic organics, treatment would become more difficult and expensive. Diversion of HHW and SQG wastes from the landfill will improve the County's ability to continue to meet those limits in the future. SECTION 2 BACKGROUND INFORMATION 2-40 The proportion of hazardous waste that is disposed of in the solid waste stream will increase as recycling programs are implemented. Liquid Waste Stream If recycling is successful, the amount of solid waste generated in King County could be reduced by as much as 65 percent by 2000. The relative percentage of hazardous waste in the waste stream would more than double if no comparable program were implemented to remove it. The effect of the increased proportion of hazardous wastes on the solid waste stream and the environment would be correspondingly greater. M Elimination of hazardous waste from the solid waste stream may be required by solid waste programs in the future. At some point in the future, King County and/or Seattle may decide to export solid waste outside the county. Receiving waste handlers, either landfills or incinerators, may prohibit the disposal of certain hazardous wastes or require that an effort be made to minimize such waste in the waste stream. Certain constituents of HHW and SQG wastes in the liquid waste stream can disrupt sewage treatment processes, or contribute to environmental contamination of local waters, land, or the atmosphere. Pollutants of concern in wastewater treatment are heavy metals No such as lead and cadmium, and toxic organics such as pesti- cides and solvents. Many such constituents can be found in household products or in substances used by SQGs. These pollutants can disrupt sewage treatment processes. For No example, methyl isothiocyanate, an herbicide, was recently discharged to the Port Orchard treatment plant and killed off the bacteria in both digesters, effectively shutting down the 'r' plant (Engel, personal communication, 1989). Sewage treatment decreases the concentration of some hazardous chemicals in the effluent discharged to local receiving waters, but the environment still receives most of those chemicals via other routes. Hazardous chemicals, for example most solvents, can pass unchanged through the No 77 M M W am WV M SECTION 2 BACKGROUND INFORMATION 2-41 primary treatment system and be discharged with the effluent. Currently, occasional exceedences of individual effluent limits occur for some of the heavy metals. In some cases where the concentration of a hazardous chemical is decreased in the liquid waste stream during sewage treatment, the portion of the chemical removed from the effluent may be discharged into the atmosphere unchanged. Some pollutants including heavy metals, phthalates (plasticizers), some pesticides and PCBs settle out with solid particles in the sludge. Future tightening of NPDES permit limitations will make compliance difficult for wastewater treatment facilities. Metro and other local districts' wastewater treatment plants operate within limits set by state NPDES permits. All current permit conditions for effluent discharges to Puget Sound are being met. However, current requirements address very few hazardous chemicals and are expected to change. In the future, permitted limits may be lowered for currently regulated substances and limits added for additional toxic contaminants. ,., Ecology is now establishing water quality standards for a number of hazardous pollutants. These may in turn result in more stringent effluent limitations in the future. For example, effluent limits have not been set for many of the solvents that currently pass through the primary sewage treatment system unchanged. Such discharges, therefore, are not addressed in Metro's or other districts' current permits. Metro believes that a responsible management position is to minimize entry of toxic substances into the system. Its Toxicant Study (1984) concluded that, "it is prudent to take steps to reduce the entry of priority pollutants into the Metro system and the environment insofar as is practicable ... the most cost-effective way to control toxicants of concern is to not allow them to get into the wastewater or environment in the first place." +r. The land application of sludge from wastewater treatment processes can be limited by its trace metals content. Metro's and other districts' currently reuse their wastewater ■* sludge in land application programs designed to fertilize the soil. The concentration of metals such as cadmium, lead and W W SECTION 2 BACKGROUND INFORMATION 2-42 M re zinc and certain organic compounds such as PCBs or pesticides limits the quantity of sludge than can be land -applied. A de- crease of metal concentrations in sludge as well as concentra- tions of such organic compounds as pesticides would make sludge easier to handle in existing uses and increase flexibility in sludge management. r Metro sludge currently meets criteria for forestry and soil improvement applications. However, EPA is in the process of setting standards for sludge quality which will include specific standards for organics and metals; this may also affect Metro's and other districts' sludge management practices in the future. In order to meet these standards, Metro and other local districts may have to tighten pretreatment standards for industry and enact other source controls. Hazardous wastes disposed of in septic systems are very likely to contribute to groundwater pollution. .. Septic tank systems rank highest of all the groundwater pollu- tion sources in total volume of wastewater discharged directly to soils overlying or near aquifers (U.S. EPA, 1984). Septic tank systems, even more so than municipal sewerage systems, are not designed to handle hazardous chemicals. Certain chemicals can cause system failure or directly contaminate groundwater through the drain field. Contaminants pass through the systems largely untreated, percolate through the r soil of the drain field and migrate to groundwater, threatening drinking water supplies. Pollution is magnified when septic systems fail. Nationally, only about 40 percent of existing .r septic systems function properly (Canter and Knox, 1985). In King County, a significant proportion of residences and businesses use septic tanks and many are in areas that rely on iO groundwater for drinking water supplies. .r Disposal of HHW and SQG waste into storm drains or directly into streams or lakes contributes significantly to nonpoint source pollution. "r Most of the storm drains in the Seattle -King County region are separate from the sanitary sewers and discharge stormwater r ■w M SECTION 2 BACKGROUND INFORMATION 2-43 �. runoff from streets and parking lots directly into the nearest stream, river, lake or bay. Local runoff studies have found most of the heavy metals in stormwater as well as organic chemicals (Galvin and Moore, 1982; Cooley, et al., 1984). National studies indicate that within the most developed industrial and commercial zones, the quality of runoff (in terms of concentration) may approach that of treated sewage from the same area (U.S. EPA, 1983). Direct dumping of household items, particularly used motor oil, and SQG wastes down storm drains represents the most readily addressed problem. Annual used oil volume in the hands of citizens is estimated to be more than one million gallons. Only about 15 percent of this used oil is recycled; more than .r one third of the people admit to dumping the waste oil directly into a storm drain, ditch or onto the ground (Galvin, et al., 1982; Ridgley and Galvin, 1982). Direct dumping of other hazardous substances, such as pesticides, is the apparent cause of all recent fish kills in King County's urban streams. Such incidents represent 35 percent of all the calls reported to the Interagency Water Quality Trouble Call System (Badger, per- sonal communication, 1988). Forty percent of Bellevue's water quality emergency calls relate to storm drain dumping (Hubbard -Grey, personal communication, 1988). Pending regulation of discharges from storm drains will require local water pollution control agencies to address proper disposal of HHW and SQG wastes. Under the Water Quality Act of 1987, EPA requires that stormwater discharges be subject to a permitting process and discharges to storm drains be reduced to the maximum extent practicable. Stormwater permits are to be issued to cities of greater than 250,000 population by 1991 with others to follow. Effluent requirements, similar to those for sewage treatment plants, may be included in the storm drain permits. Diversion of HHW and SQG wastes now dumped down storm drains will help keep effluent contamination within permit limits. r Ecology water quality programs are focusing more and more on nonpoint sources of pollution. Stormwater is being dealt r with on a watershed basis through the state's nonpoint source pollution program. Permits and plans required under this W SECTION 2 BACKGROUND INFORMATION 2-44 program must address household and other generators of hazardous waste. Implementation of local hazardous waste plans in the region is included as an element in the Puget Sound Water Quality Authority's Management Plan, fulfilling state requirements. The Lake Union Interim Action Plan also includes implementa- tion of the Local Hazardous Waste Plan: "Implementation of the plan will help to reduce pollution loading of Lake Union from household hazardous wastes and from industrial effluent from businesses located on the Lake Union shoreline." Most of the potential industrial sources are SQGs (Office for Long- range Planning, 1988). Worker Safety HHW and SQG wastes in the municipal waste stream . increases the risk of accidents on the job and chronic exposure to hazardous chemicals for garbage collectors, and workers at transfer stations, landfills and sewerage systems. The City of Los Angeles Waste Management Division has documented injuries to trash collectors from exposure to hazardous materials. Between February 1, 1980 and MV rr .N M .r r-� No No to no 77 go No 17 Worker exposure to hazardous waste is difficult to measure. Two types of exposure are of concern: 1) on-going (chronic) exposure to low levels of hazardous substances; and 2) acute exposure to a dangerously high level of a hazardous substance through accidents. Little testing has been done to measure chronic exposure levels. Testing such levels at solid waste facilities, for example, is difficult because conditions are constantly changing. Yet, tests that have been conducted ® indicate current exposure limits are probably being met. In the last two years, six incidents affecting thirteen people &-D have occurred at City and County transfer stations in which workers have been hurt as a direct result of hazardous wastes in the solid waste stream. Over 50 days of work were lost. For example, two people were injured in a fire at a transfer station caused by hazardous materials and forty-eight days of work were lost (Solid Waste Utility, 1988). In another inci- dent four people were overcome by fumes, possibly from dry chlorine dumped in the transfer station. The transfer station had to be evacuated (Lambert, personal communication, 1988). The City of Los Angeles Waste Management Division has documented injuries to trash collectors from exposure to hazardous materials. Between February 1, 1980 and MV rr .N M .r r-� No No to no 77 go No 17 W M SECTION 2 BACKGROUND INFORMATION 2-45 November, 1987: 40 trash collectors experienced chemical burns; 50 workers inhaled noxious fumes; and 120 workers came in contact with unidentified chemicals (Fabrikant, personal communication, 1988). Other workers are also at risk -- everyone from sewage " treatment workers to firefighters to employees of businesses using and disposing of hazardous materials. Firefighters are particularly at risk when they must enter a burning building containing unidentified hazardous materials. Washington State Department of Labor and Industries records indicate that there were 72 claims in King County in 1987 for incidents involving hazardous materials (Department of Labor and Industries, 1988). These covered all kinds of occupations including ' firefighters, construction workers, and machine operators. I Impacts on the Public and the Communis W i�� Long-term storage of HHW and SQG wastes in basements and garages increases the risk of exposures and fires. Long-term storage of hazardous wastes in the home or business poses a risk to public safety. Storage is a common option used for old, unwanted products, until some event results in their removal. Poisonings, spontaneous fires and exposure to hazardous fumes in the event of a fire are all likely results of large inventories kept in the back room, basement or garage. Analysis of data from the State Fire Marshal's Office indicates that about 24 percent of reported fires in Washington, over 6,000, were caused by hazardous materials (National Fire Incident Report System, 1988). In addition to fires and accidents, some studies indicate that health risks may be associated with chronic low-level exposure to hazardous materials. A study of leukemia in children in Los Angeles, for example, found an increased risk of leukemia in children whose parents used pesticides in the home; the risk increased with frequency of use (Lowengart, et al., 1987) The Seattle Poison Control Center reports that nearly 25 percent of calls concern poisonings from hazardous household products. One study reported that about 30 percent of calls received by Poison Control Centers in Minnesota involved so SECTION 2 BACKGROUND INFORMATION 2-46 "' substances that could be defined as household hazardous waste (Ridgley, 1987). .n Disposal of HHW and SQG waste in the municipal waste streams and the environment can cause property damage as well as injury. we In at least one local incident gasoline poured down a storm drain resulted in serious and costly damage. Half of a residential street in the White Center neighborhood of Seattle was damaged in 1982 when between one and five gallons of gasoline exploded in the storm drain (Seattle Times, July 19, „ 1982). Numerous other such incidents have been reported. Spills and poor management of hazardous wastes can result in long term liability for property owners, lending institutions and insurance companies. SQGs are not exempt from the lifetime liability for environ- mental contamination under state and federal Superfund laws. When contaminated property changes hands, banks, new pro- perty owners or insurance companies may also become liable for any clean up costs. Many lending institutions now require purchasers of non-residential properties to furnish detailed information concerning past uses of the property and the potential for contamination from those uses. Some require an independent inspection to uncover any signs of potential contamination (Dorrigan, personal communication, 1988). For the small business owner, for whom the business property may be a large portion of his or her assets, liability for clean ups can be financially devastating. Summary As King County's population continues to grow and environ- mental standards continue to get stronger, we must do as much as we can to reduce all waste production, but particularly that .o waste which is hazardous. A program that effectively manages hazardous wastes at the local level will not only meet state requirements, but will also minimize problems and help protect 2d public health and the environment. we SECTION 2 BACKGROUND INFORMATION 2-47 PROGRAM NEEDS Education Programs Household Hazardous Waste 0 Existing programs directed at household and small quantity generator hazardous waste, as described above, are limited in scope and resources. This section describes the existing program limitations and program needs as identified through the public involvement process. Education programs should provide information to: 1) enable the citizen to identify hazardous products; 2) encourage the proper use and disposal of hazardous products; and 3) encourage waste reduction and minimization including, where possible, the use of less hazardous products. The programs should provide continuous, consistent and practical information through various media to reach targeted audiences. A number of agencies direct some education activities at households and small quantity generators, but funding is very limited. Several brochures, fliers and other printed materials are available; but there is little outreach to targeted groups, for example consumers or schools. Neither households nor busi- nesses have access to much information on product substitution and waste minimization. An education program should lead to a reduction in the amount of HHW entering the solid and liquid waste streams. Product substitution, treating wastes at home, and recycling are all methods that can be used to reduce the amount of hazardous waste generated. The results of the survey of King County residents and the focus group discussion indicate that the public is unaware that household products may be hazardous. Overall, 52 percent of the survey respondents did not, when asked, identify ay products in their homes that they would classify as "hazar- dous". Yet at the same time, when asked if they had specific hazardous products in their home, the vast majority had one or more of these products (see Figures 2-12 and 2-13). Most of these products they disposed of through the garbage (Figures 2- 8 through 2-11). SECTION 2 a i0a 90 BO 70 60 50 40 30 20 10 BACKGROUND INFORMATION CLEANERS PEST PAI17 AUTO BATTERY B[0 Figure 2-12. PRODUCTS LISTED AS HAZARDOUS BY KING COUNTY RESIDENTS too 90 No 70 CLEANERS PEST PAINTS AUTO BATTERY BED Figure 2-13. HAZARDOUS PRODUCTS IDENTIFIED IN THE HOME 2-48 i a SECTION 2 BACKGROUND INFORMATION 2-49 The focus group discussions supported these results, but at the same time focus group participants thought education could be effective in getting people to change their behavior. Partici- pants in the workshops were even more specific. They felt consumers need to be informed of what hazardous wastes are and how to dispose of them properly. To accomplish this they recommended education efforts in schools and for the public, using various media, and emphasizing waste reduction and alternative products. Workshop participants stressed the need for education programs that target waste reduction. They also felt that research was ® needed to identify and develop nonhazardous products. Focus group participants emphasized the importance of cost and con- venience stating that "Some people will buy the cheapest pro- ducts even if they are more hazardous," and "I'm not likely to mix up a home remedy [that is less hazardous] when it's easier to pick up a product in the store." W Small Quantity .. Generators Education programs targeted to businesses should provide in- formation on: 1) the regulatory requirements affecting busi- nesses, and 2) appropriate waste management technologies. ,,. Many businesses do not know that they generate hazardous waste, or erroneously believe that, since they do not produce large amounts of hazardous waste, they are not subject to any proper waste management procedures. Other businesses are not .. aware that they generate amounts of hazardous waste that fall under state regulation. SQGs are further confused by the variety of local regulations containing different standards and waste management requirements. Small companies lack the time, money and personnel to make these determinations and to keep up to date with changing regulations. Education programs need to provide industry -specific informa- tion on regulations and management options in comprehensible language. Participants in the SQG focus group had a lot to say about the need for accessible information. They found it difficult to get the right information from government agencies. They often had to contact a number of people to try to get any answers, and information from different agencies was inconsis- tent. Regulations appear to change constantly and are con- fusing. They want to be able to get clear, consistent answers without the fear that the government would be "down our W SECTION 2 Collection Programs Household Hazardous Waste BACKGROUND INFORMATION 2-50 1 throat". Both focus group and workshop participants felt that education programs should be specifically targeted to SQGs, and that the best way to educate businesses was through the trade associations targeting specific industries. SQGs also need cost-effective, practical waste management options. New technologies are needed to manage some of the wastes SQGs typically generate. Businesses also need to be made aware of available technologies and alternative practices. Universities, private industry and laboratories are resources that could be tapped for industry -specific solutions to waste management problems. Participants in the SQG focus group thought manufacturers had a specific responsibility to develop nonhazardous products and to help with disposal of hazardous wastes, perhaps by taking back excess materials. Existing HHW collection programs have been limited in the service they provide and the amount of waste collected. Collection day events occur infrequently, and although they have been well attended have collected only five percent of the amount of waste generated annually. The area's on-going collection programs -- City of Seattle South Transfer Station, Health Department pesticide collection and others -- while providing more continuous service, do not have adequate capacity or accessibility to meet the public need. As the public becomes more informed about the proper management of HHW, demand for collection and disposal services will increase. The need for convenient, economical disposal options is already evidenced by the record-breaking attendance at the last several HHW round -up events in King County. Collection options include: door-to-door or curbside pick up, mobile collection units, permanent collection sites and annual or semi-annual round -up events. Seventy-four percent of the respondents to the telephone survey indicated they would be more likely to take advantage of curb- side pickup of hazardous wastes. However, all collection methods included in the survey were acceptable to the majority of survey respondents (Figure 2-14). Respondents were asked we so No ■r no r we No as 1W so M rr M SECTION 2 BACKGROUND INFORMATION 2-51 ~ how far they would be willing to drive to dispose of their waste: 31 percent were willing to travel up to 2 miles and 49 percent up to 10 miles (Figure 2-15). Asked how much they would be willing to pay for disposal, 59 percent indicated they were willing to pay up to five dollars (Figure 2-16). Focus group participants felt that disposal options must be convenient and inexpensive. One person said, "The local government has to come up with a program that is both convenient and doesn't cost too much. I'm willing to spend SOME money and a LITTLE extra time, but there needs to be a balance of convenience and cost." Workshop participants felt the present collection system is not convenient. Small .. Quantity Generators Until recently, no collection services specifically for small quantity generator waste existed. Hazardous waste brokers, r small-scale entrepreneurs who act as intermediaries between the small quantity generators and TSD facilities, have begun to serve this market. As with households, SQGs who want to ,. dispose of their hazardous wastes in an environmentally sound manner have far too few options open to them. Focus group participants thought that some kind of Round -up should be held for SQGs. Costs and accessibility are significant barriers hindering proper disposal of SQG wastes. The strict regulation of hazardous waste disposal by the state and federal governments, and the consequently limited number of licensed TSDs, result in high disposal costs for all hazardous wastes, including those of SQGs. The required laboratory testing of wastes is very costly, especially when an expensive battery of tests must be performed for a relatively small amount of waste. These costs are a significant disincentive for SQGs to dispose of their wastes in an environmentally sound manner. Regulation and Compliance r The regulatory framework for disposal of HHW and SQG wastes is inadequate and confusing. The local regulatory mechanism is comprised of various public agencies responsible r. for regulating separate elements of the solid and liquid waste streams under the authority of various federal, state and local on W SECTION 2 BACKGROUND INFORMATION 2-52 0#6 How much would you be willing to pay per visit for disposal of your hazardous waste at collection site? 15% 4% 10% 59% < $5 $6-$9 El $10 El No Pay El DK/NR Figure 2-14. PREFERRED DISPOSAL OPTIONS FOR HHW 0#3 Which disposal method are you more likely to use? 100%.. ............... ................. 9 0 % .............. 80% 7nol 20% 10% 0%1 Docr Curb Special Permanent Figure 2-15. PREFERRED TRAVEL DISTANCES FOR HHW DISPOSAL El DK/NR 60% El Not Likely Percent of Respondents 50% M Less Likely 40% N More likely 20% 10% 0%1 Docr Curb Special Permanent Figure 2-15. PREFERRED TRAVEL DISTANCES FOR HHW DISPOSAL r r SECTION 2 r r ro r rw M M M r W W 5% BACKGROUND INFORMATION 0#4 How far would you drive to dispose of hazardous wastes? 4% 49% 1% E < 2 miles in > 10 miles 0 up to 20 miles El > 20 miles ❑ Wouldn't Drive 0 Don't Know Figure 2-16. PUBLIC WILLINGNESS TO PAY FOR HHW DISPOSAL 2-53 SECTION 2 BACKGROUND INFORMATION 2-54 •r M .r laws. The complex interwoven nature of the agencies' respon- sibilities creates a potential for gaps and overlaps within the regulations. Since the regulations were written and programs were developed before SQGs were defined as a separate cate- gory of hazardous waste generators, it is not always clear if the regulations address SQGs in part or at all. Many small quantity generators, as well as citizens, are not aware that regulations exist for proper disposal of their hazardous wastes. At this time, local regulations pertaining to SQG hazardous waste management are sporadically enforced and compliance with applicable regulations is poor. Inspections of businesses are inadequate. The inspections that do occur focus on "regu- lated" generators. Unfortunately, most local agencies have insufficient funds and staff to conduct adequate inspections. The majority of inspections of SQGs are conducted on a com- plaint/request basis by the Health Department, Metro or the local fire department. These inspections are infrequent and usually result from an emergency situation. The lack of an enforcement presence results in noncompliance by SQGs. r 777 VW SECTION 2 BACKGROUND INFORMATION 2-55 REFERENCES Badger, B., Interagency Water Quality Trouble Call Coordinator, Metro. Personal �. communication, June, 1988. Baroga, Rico, G. Kato, J. Lowe, J. Lorbeir, J. McGilton. A Survey of Small Quantity Hazardous Waste Generators: The Puget Sound Experience, Tacoma -Pierce County Health Department, Thurston County Health Department, Seattle -King County Department of Public Health, City of Seattle Engineering Department, Seattle, Washington, 1986. Bennett, Elizabeth, J.Goldberg, P. Hamilton, M. Marchi Lundt, D. Nash, J. Sammerhays- Ayco, S. Toteff. Household Hazardous Waste Public Information and Education Materials for Washington State, Public Education Subcommittee of the King County Hazardous Waste Interagency Coordinating Committee, Seattle, Washington, 1988. Bobbink, S., Seattle Poison Center. Personal communication, November, 1988. Cal Recovery Systems. Characterization and Impacts of Nonregulated Hazardous Waste in Municipal Solid Waste of King County, Puget Sound Council of Governments, Seattle, Washington, December, 1985. Canter, L.W., R.C. Knox. Septic Tank System Effects on Groundwater Ouality, Chelsea, i Michigan & Lewis, 1985. Cooley, R, et al. Toxicant Pretreatment Planning Study Technical Report A2: Collection System Evaluation, Municipality of Metropolitan Seattle, Seattle, Washington, 1984. Department of Labor and Industries. Claims Involving Contact with Radiation, Toxic or Noxious Substances, 4/1/86 to 9/12/88, Olympia, Washington, 1988. DeWalle, F. B., R. M. Schaff. "Groundwater Pollution by Septic Tank Drainfields," IN Environ. Eng. Div., ASCE (EE3): 641-646, 1980. Dorrigan, L., Washington State Department of Ecology. Personal communication, 1988. Engel, C., Kitsap County Sewer District. Personal communication, January, 1989. Fabrikant, R., Sanitary Engineering Associate, Department of Public Works, Los Angeles, r California. Personal communication, November, 1988. Galvin, D. V., R.K. Moore. Toxicants in Urban Runoff, Municipality of Metropolitan Seattle, Seattle, Washington, 1982. n Im SECTION 2 BACKGROUND INFORMATION 2-56 Hasselman, S., M. Merrill Jr., J. Gall. Toxicant Pretreatment Planning Study - Technical Report B: Pilot Plant Studies, Municipality of Metropolitan Seattle, Seattle, Washington, 1984. Hathaway, S.W. Sources of Toxic Compounds in Household Wastewater, U.S. Environmental Protection Agency, Municipal Environment Research Lab, #600/2-80-128, Cincinnati, Ohio, 1980. Hubbard -Grey, S., Project Coordinator, City of Bellevue Storm and Surface Water Utility. Personal communication, June, 1988. King County Departments of Parks, Planning, and Resources. 1986 Annual Growth Report, King County, Washington, 1986. King County Departments of Parks, Planning, and Resources. 1987 Annual Growth Report, King County, Washington, 1987. King County Solid Waste Division. Solid Waste Management Alternatives, Programmatic Final Environmental Impact Statement, King County, Washington, September, 1988. Lambert, D., King County Solid Waste Division. Personal communication, October, 1988. Land Development Information System. Onsite Sewage Disposal Systems in King Count3L Their Land Use Implications. King County Parks, Planning and Resource Department, Seattle, Washington, 1986. Lowengart, R. A., J. M. Peters, C. Cicioni, J. Buckly, L. Bernstein, S. Preston -Martin, E. Rappaport. Childhood Leukemia and Parents' Occupational and Home Exposures, Journal of the National Cancer Institute, Vol. 79. No. 1. July, 1987. Metro Water Quality Division. Summary Report - Household Hazardous Waste Disposal Project. Metro Toxicant Program Report No 1A, Municipality of Metropolitan Seattle, Seattle, Washington, August, 1982. Metro. Sewage Disposal Alternatives: A Look at the Problem of Faulty Septic Tank Systems and Alternative Methods of Sewage Disposal for King County Washington. Municipality of Metropolitan Seattle, Seattle, Washington, 1977. Moehring, J. Seattle Residential Development Report, City of Seattle Office for Long- range Planning, Seattle, Washington, 1988. Monk, M., King County Solid Waste Division. Personal communication, November, 1988. M at do so to No 0 a M SECTION 2 BACKGROUND INFORMATION 2-57 Morley & Associates, 1987. Household Hazardous Waste Management Evaluation Project - Task Resort - Draft Needs Assessment, City of Seattle Solid Waste Utility, Seattle, Washington, December, 1987. Mortimer, R. Household Hazardous Waste Round -Up: Evaluation and Recommendations for the City of Seattle, City of Seattle Solid Waste Utility, Seattle, Washington, September, 1987. National Fire Incident Report System. "Listing of All Fire Elements by Frequency of Occurrence." Report Period: 1/1/87 to 12/31/87, 1988. Office of Financial Management Forecasting Division. 1988 Population Trends for Washington State, Olympia, Washington, April 1, 1988. Office for Long -Range Planning. Lake Union and Ship Canal Water Quality Management Program Interim Action Plan, City of Seattle, Seattle, Washington, 1988. PSCOG. Population and Employment Forecasts 1984, Puget Sound Council of .. Governments, Seattle, Washington, June, 1984. PSCOG. Population and Employment Forecasts 1988, Puget Sound Council of Governments, Seattle, Washington, June, 1988. Ridgley, S. Toxicants in Consumer Products, Municipality of Metropolitan Seattle, Seattle, Washington, 1982. Ridgley, S. Hazardous Waste from Minnesota Households, Minnesota Pollution Control Agency, St. Paul, Minnesota, 1987. Ridgley, S., D.V. Galvin. Summary Report: Household Hazardous Waste Disposal Project, Municipality of Metropolitan Seattle, Seattle, Washington, 1982. Rolla, T., Seattle -King County Department of Public Health, Technical Section. Personal communication, April, 1988. R.W. Beck & Assoc. Waste Characterization Study, King County Solid Waste Division, September, 1988. SCS Engineers. Development of a Hazardous Waste Management Plan for Small Quantity Generators: North Hollywood Pilot Studer Final ReportHazardous Waste Inventory, Southern California Association of Governments, Los Angeles, California, November 1984. Seattle Times, "Blast Damage," page C2, July 19, 1982. 7 ow e SECTION 2 BACKGROUND INFORMATION 2-58 Solid Waste Utility. Safety Office Quarterly Reports, January, 1984 to March, 1988, City .r of Seattle, Seattle, Washington. Thomas, J., Washington State Department of Revenue. Personal communication, January, 'm 1989. U.S. Environmental Protection Agency. Results of the Nationwide Urban Runoff Program. Volume 1 -- Final Report, U.S. EPA, Water Planning Division, Washington, D.C., 1983. U.S. Environmental Protection Agency. Evaluation of Septic Tank System Effects on Ground Water Quality, U.S. EPA #600/2-84-107, Ada, Oklahoma, 1984. Yerkes, T.W., W.C. Swofford, S.A. Whitman, C. Thompsen, T. Clements. Surveys and Audits of Major and Minor Small Quantity Business Generators in the Seattle -King County Area, Seattle -King County Department of Public Health, Seattle, Washington, ■++ unpublished. .r ■w r r D I SECTION 3 PLAN DESCRIPTION 3-1 PLAN DESCRIPTION This section presents the Plan for management of HHW and SQG wastes in Seattle and King County. Implementation and funding are also described. Lead agency responsibilities for the various programs are assigned. As Ecology's guidelines require, the Plan focuses on the first 'W five years of implementation but also addresses a 20 -year horizon for meeting waste diversion goals. The Plan is an intensive effort to divert the maximum amount feasible of r. HHW and SQG wastes from disposal in municipal waste streams and the environment. Over the 20 -year life of the Plan, about 313,000 tons of waste will be diverted. Total •. program costs are approximately $178 million, yielding an average cost per ton of waste diverted of $568.' The Plan addresses all aspects of HHW and SQG waste management. Six components are intended to provide a comprehensive approach to the problems of managing these wastes (as described in Section 2): HHW Education .. HHW Collection SQG Education and Technical Assistance SQG Collection W Compliance Evaluation M The components emphasize: education for waste reduction; • development and promotion of convenient and accessible collection options; • where necessary, incentives for compliance with federal, state and local regulations; and, 'The figure was derived by dividing the total 20 -year cost of the Plan by the total tonnage of waste diverted. Yearly cost per ton diverted figures will vary considerably around this average (see Table 3-3). on no SECTION 3 ZZZ REDUCE RECYCLE TREAT MQNERATE I' IANDriLL Figure 3-1. Washington State Waste Management Priorities PLAN DESCRIPTION 3-2 • an evaluation mechanism for feedback on program effectiveness. The Plan will achieve its goal of diverting wastes from municipal waste streams and the environment through a combination of waste reduction and waste collection program elements. These program elements are listed in Table 3-1. The Washington State legislature defines hazardous waste reduction as, "All ... practices that reduce, avoid or eliminate the amount of waste generated." In the context of this Plan, waste reduction refers to those wastes that are never generated in the first place, either because the hazardous product is not used at all, or because it is used in its entirety. An intensive and aggressive education and technical assistance program, targeting both householders and SQGs, will emphasize waste reduction. Waste reduction will eliminate approximately 44 percent of HHW and 23 percent of SQG wastes that could have been generated each year when the Plan has been fully implemented. Waste reduction goals for specific waste cate- gories (oil, paints, solvents, pesticides, etc.) form the basis of the overall waste reduction goal. The rationale for the waste category specific goals is presented in Appendix B. Waste reduction is a more cost-effective strategy for diverting HHW and protecting public health and the environment in the long term than is collection and disposal. The greatest single cost to local governments in this Plan is disposal of HHW. Disposal of each ton of HEW collected under the Plan will cost an estimated $1300. That same ton of waste will cost local governments far less if consumers decrease their purchase and use of hazardous products and therefore the amount of waste they generate. Similar savings for businesses result when waste reduction is emphasized over collection and disposal of SQG wastes. In addition, a strategy emphasizing waste reduction is consis- tent with the State's waste management priorities (Figure 3-1). For wastes not eliminated through waste reduction programs, collection programs will be provided, either directly by local governments, or through the private sector. To the extent reasonable, given technical availability and costs, recycling of collected wastes will be emphasized. The Plan includes M .■ so 4W wr n] as me 1W .r Ta A SECTION 3 PLAN DESCRIPTION Table 3-1. PROGRAM ELEMENTS Household Hazardous Waste Education • Public Information and Outreach • Telephone Information Line • Schools Program Household Hazardous Waste Collection and Waste Handling • Permanent Collection Facilities b"'0 Mobile Collection Facilities • Pickup Service for Homebound • Targeted Waste Collection and Recycling Paint Recycling Household Battery Collection/Recycling Auto Battery Collection/Recycling Collection of Used Motor Oil 11 Small Quantity Generator Education and Technical Assistance Information Development and Resources • Passive Waste Exchange • Telephone Information Line it Resource Library • Promotion of Waste Reduction, Recycling and Treatment Programs • Waste Characterization and Treatment Feasibility • On -Site Consultation Small Quantity Generator Collection and Waste Handling Mobile Collection Facilities • Auxiliary Collection Facilities • Subsidized Collection rr Compliance • Interagency Regulatory Analysis Committee • Enhancement of Local Ordinances 0 Response Network • Surveys and Audits Evaluation To 3-3 ■rr SECTION 3 PLAN DESCRIPTION 3-4 funding for special projects designed to test and promote aw recycling (described below). Collection goals were established based on the progressive .w development of collection facilities. These facilities are phased in over time due to financial constraints. Use of collection facilities is expected to increase over time due to public so education and promotion efforts. Figures 3-2 and 3-3 show how waste diversion is a combina- no tion of waste reduction and collection, for FH --IW and SQG waste, respectively. The Plan includes a variety of programs to strengthen local .r regulations that prohibit disposal of HHW and SQG wastes in municipal waste streams and to identify and work with SQGs so to bring them into compliance with federal, state and local regulations. While outlining specific programs, the Plan also allows for flexibility and creativity. The specific programs described in the Plan are not the only possibilities, and these programs may be modified as new information is obtained. As the programs 11°' are implemented, their effectiveness will be evaluated. Mar- ginally effective programs will be discontinued or modified. Successful programs may be expanded beyond the scope indi- cated here. Some of the programs are experimental and can be affected by factors outside the control of local governments, such as fluctuating markets for recycled materials, or changing federal or state regulations. The Plan may have to be modified to take such changes into account. The Plan is also flexible in terms of which agency takes responsibility for its different elements. Suburban cities, for example, may want to have a collection facility within their boundaries, sponsor a public education program or participate in SQG technical assistance or compliance programs. Such participation is consistent with the Plan. In short, the Plan represents a commitment from local governments to address the problems of HHW and SQG hazardous wastes, and outlines the strategies and the initial implementation steps needed. It establishes waste diversion goals, desirable levels of service, and the components needed, for a comprehensive Plan to meet state requirements. The t 9 aw w rr. SECTION 3 PLAN DESCRIPTION 3-5 '2000 '0000 8000 T S 5000 'I000 2000 0 TOTAL WgSTE GENED WITLgUT PROGRAMERAT� {fir MUNICIPAL DISPOSAL COLLECTED AND RECYCLED COLLECTED AND DISPOSED 1 3 5 l 9 11 '3 15 '.l 19 YEARS Figure 3-2. PROJECTIONS OF HHW MANAGEMENT 25000 20000 5000 5 8 .• '3 'S 7 '9 YEARS Figure 3-3. PROJECTIONS OF SQG WASTE MANAGEMENT The top line in each figure shows the amount of hazardous waste projected over the next twenty years assuming no program exists. At the point where the second and third lines meet, the amount of wastes remaining in solid waste, wastewater and environment will be negligible. [Note that the vertical scales of the two figures are not identical.] SECTION 3 PLAN DESCRIPTION 3-6 1 details of the Plan are expected to change over time as conditions change. The following section describes the Plan by component, in detail. Costs are summarized in Table 3-2. Waste diversion and cost per ton of diverted waste is summarized in Table 3-3. All costs are presented in 1989 constant dollars. Staffing levels are described below and may represent new or existing positions. In some cases, staffing levels reflect tasks that will be carried out by a variety of people for a small portion of each individual's time. In other cases, staffing levels reflect dedicated positions. Some programs lend themselves to imple- mentation by consultants. Where this is appropriate, program coordinators would manage contracts, and some of the funds that appear in Table 3-2 would be used for consultants. HHW Education Component A major emphasis of the HMW education program is waste reduction. The most effective and cost-effective way to prevent HHW from entering the environment is to reduce the amount of hazardous products purchased and discarded and, _ therefore, the amount of waste generated. Widespread 0- education is the best way to accomplish this end. 0=0 O C9 0 0 .••' The goals of the HHW Education Component are: '• to educate the broadest possible audience about HHW; •� to promote waste reduction; • to explain the need for careful disposal of these wastes. This will be accomplished by a series of programs designed to achieve the following: • to educate youngsters and young adults, and through them, their parents, about the proper management of HHW; • to reach out to targeted audiences, for example hobbyists, to provide information on managing specific types of waste; • to create and maintain information resources to provide answers to citizens' questions; and • to alert consumers to hazardous products, identify less hazardous alternatives and encourage changes in purchasing practices. E� go a* M .r ob .r M .s M .. { } i Table 3-2. BUDGET SUMMARY (1989 dollars, rounded to nearest thousand) HHW EDUCATION COMPONENT PUBLIC INFORMATION AND OUTREACH General Promotion and Publicity Waste Reduction Promotion HHW TELEPHONE INFORMATION LINE SCHOOL PROGRAMS ADMINISTRATION/COORDINATION HHW EDUCATION COMPONENT TOTAL HHW COLLECTION COMPONENT PERMANENT FACILITIES (Capital costs) Operating costs MOBILE FACILITIES (Capital costs) Operating costs PROMOTION OF COLLECTION FACILITIES TARGETED WASTE COLLECTION/RECYCLING ADMINISTRATION/COORDINATION HHW COLLECTION COMPONENT TOTAL HHW PLAN TOTAL 1990 1991 1992 1993 1994 1999 2004 2009 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 95,000 120,000 170,000 245,000 80,000 80,000 80,000 150,000 200,000 250,000 400,000 500,000 550,000 550,000 550,000 50,000 75,000 100,000 100,000 125,000 150,000 150,000 150,000 175,000 255,000 235,000 210,000 200,000 160,000 155,000 155,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 $531,000 $731,000 $811,000 $986,000 $1,176,000 $1,046,000 $1,041,000 $1,041,000 106,000 106,000 106,000 106,000 629,000 885,000 1,092,000 1,440,000 2,044,000 4,279,000 5,534,000 6,408,000 33,000 33,000 331,000 663,000 994,000 994,000 994,000 994,000 994,000 994,000 25,000 25,000 25,000 25,000 25,000 7,000 7,000 7,000 100,000 125,000 150,000 200,000 150,000 200,000 200,000 200,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 1 281,000 $1,893,000 $2,423,000 $2,821,000 $3,269,000 $5,536,000 $6,791,000 $7,665,000 $1,812,000 2 624 000 $3,234,000 $3,807,000 $4,445,000$6,582,000$7,832,000 $8,706,000 Table 3-2. BUDGET SUMMARY (Continued) SQG EDUCATION COMPONENT INFORMATION DEVELOPMENT AND RESOURCES Education Materials Development Seminars and Workshops Telephone Information Line Resource Library Passive Waste Exchange TECHNICAL ASSISTANCE PROGRAMS Waste Reduction, Recycling, and Treatment On-site Consultation Waste Characterization and Treatment ADM IN ISTRATION/COORDINATION SQG EDUCATION COMPONENT TOTAL SQG COLLECTION COMPONENT Mobile Collection Facilities Auxiliary Collection Facilities Subsidy of SQG Collection Costs Promotion of Collection Services Adm inistration\Coordination SQG COLLECTION COMPONENT TOTAL SQG COMPLIANCE COMPONENT Regulation changes and enhancement Response network Surveys Audits Adm inistration\Coordination SQG COMPLIANCE COMPONENT TOTAL SQG PLAN TOTAL 1990 1991 1992 1993 1994 1999 2004 2009 95,000 95,000 95,000 95,000 95,000 95,000 95,000 95,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 52,000 52,000 104,000 104,000 104,000 104,000 104,000 104,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 75,000 95,000 95,000 95,000 95,000 95,000 95,000 95,000 95,000 100,000 200,000 195,000 195,000 195,000 160,000 160,000 160,000 170,000 235,000 256,000 256,000 256,000 256,000 256,000 256,000 65,000 302,000 385,000 385,000 345,000 315,000 315,000 315,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 $758,00 1 160 000 $1,311,000 $1,311,000 $1,271,000 $1,206,000 $1,206,000 $1,206,000 245,000 145,000 365,000 240,000 234,000 0 190,000 120,000 295,000 230,000 40,000 143,000 218,000 297,000 380,000 40,000 40,000 40,000 40,000 40,000 56,000 56,000 56,000 56,000 56,000 $381,00 574 00 $799,000 $928,000 $940,000 100,000 100,000 50,000 50,000 50,000 6,000 6,000 6,000 254,000 246,000 316,000 349,000 349,000 349,000 349,000 349,000 70,000 102,000 173,000 205,000 276,000 309,000 309,000 309,000 170,000 224,000 256,000 327,000 359,000 635,000 618,000 618,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 56,000 $650,000 $728,000 $851,000 $987,000 $1,090,000 $1,355,000 $1,338,000 $1,338,000 $1,789,000 2 462 000 $2,961,000 $3,226,000 $3,301,000 $2,561,000 $2,544,000 $2,544,000 w 00 Table 3-2. BUDGET SUMMARY (Continued) EVALUATION COMPONENT ADMINISTRATION/COORDINATION HHW PROGRAM EVALUATION SQG PROGRAM EVALUATION EVALUATION COMPONENT TOTAL 1990 1991 1992 1993 1994 1999 2004 2009 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 27,000 30,000 15,000 15,000 40,000 7,000 12,000 7,000 68,000 40,000 13,000 13,000 40,000 4,000 6,000 4,000 $140,000 $115,000 $73,000 $73,000 $125,000$56,000$63,000 0 381 $56,000 PLAN TOTAL $3,741,000$5,201,000$6,268,000 $7,106,000 $7,871,000$9,199,000$10,439,000 $11,306,000 Table 3-3. WASTE DIVERSION SUMMARY 1990 1991 1992 1993 1994 1999 2004 2009 Tons of HHW Waste Diverted 1,059 1,484 1,930 2,209 2,765 7,296 9,350 11,050 Cost per Ton Diverted $1,711 $1,768 $1,675 $1,724 $1,608 $902 $838 $788 Accumulated Municipal Disposal (tons) 5,421 5,166 4,890 4,801 4,435 964 neg.' neg.' Tons of SQG Waste Diverted 0 381 782 1,204 1,650 6,555 15,246 22,110 Cost per Ton Diverted N/A $6,463 $3,787 $2,680 $2,001 $391 $167 $115 SQG Accumulated Municipal Disposal (Tons) 12,960 12,909 12,868 12,806 12,750 9,965 3,814 neg.' Tons of HHW and SQG Waste Diverted 1,059 1,865 2,712 3,413 4,415 13,851 24,596 33,160 Cost per Ton Diverted $3,534 $2,789 $2,311 $2,082 $1,783 $665 $424 $341 Accumulated Municipal Disposal (Tons) 18,381 18,075 17,758 17,607 17,185 10,929 3,814 neg.' 'negligible amount w SECTION 3 HMW Education Program Elements PLAN DESCRIPTION 3-10 The HHW education component will be managed by an "edu- cation program coordinator," based in the Seattle -King County Department of Public Health (Health Department). The coor- dinator will develop educational materials and oversee and provide assistance to other agencies' efforts in this area. The coordinator will work with staff from other jurisdictions and agencies who are implementing special events and education programs, to assure that the HHW education program is com- prehensive, consistent, reaches all King County residents, and is not duplicative or wasteful of effort (see job description, Appendix B). Annual costs for the education component range from $530,000 in 1990 to $1.2 million in 1994; thereafter yearly costs are approximately $1 million. These funds will be allocated to agencies performing specific education activities, according to the level of funding available for each program element each year. The education coordinator will be responsible for establishing priorities for program development. The highest priority programs will be implemented in the early years, and additional and more extensive programs will come on-line as funding levels increase. Public Information and Outreach will actively inform and educate the public through: • the development and distribution of printed materials, slide shows, and videos. • special events and activities intended to encourage public participation in waste reduction, recycling and collection activities; • media publicity; and, • special projects aimed at target audiences or waste streams. This program is divided into two areas: General Promotion and Publicity, and Waste Reduction Programs. Both the waste reduction and general promotion activities described in Ap- pendix A are examples only; they are not intended to define the limits of possible education programs. Staff for these programs are expected to explore new ideas and identify specific target audiences or waste handling issues for educational programs. so M nr at ad .r rI 1 1 M r SECTION 3 PLAN DESCRIPTION 3-11 The equivalent of two full-time staff (FTV will be dedicated to these programs; however, activities will be carried out by several agencies. Metro, the City of Seattle (Seattle), and King County Solid Waste Division (King County) will conduct general promotion and publicity programs, while Metro and Seattle will also be responsible for waste reduction programs. HHW Collection Component The HHW collection component will feature several collection programs that, when combined, provide an efficient and 'FTE stands for "full-time equivalent." A staffing level of "one FTE" could indicate one, full-time, dedicated staff, or it could indicate that several staff spend a portion of their time on a particular task, but that the total effort is equivalent to one full-time staff position. This concept is used throughout the Plan to describe staffing levels. 'The expanded Hazards Line will also serve SQGs; see description under SQG Education and Technical Assistance Component. 1 r. A Telephone Information Line will provide readily available information to all King County residents on waste reduction, and the proper storage, handling and disposal of HHW. '• Printed information will also be available on request. nO0 ` Currently, the Health Department Hazards Line (296-4692) •• performs this function. This service will be expanded from •� 1.25 FTE staffing level to three FTEs by 1995.3 The Hazards Line receives approximately 50-60 calls per day. The number of calls is expected to increase as public awareness increases with implementation of the Plan. A Schools Program will teach students to identify hazardous products in the home, safer alternatives to hazardous products, and proper disposal methods for household wastes. Homework assignments could involve and educate parents also. The program will be coordinated by King County, with one full- time dedicated staff beginning in 1990. During the first year (1990) the coordinator will be responsible for curricula and program development. Starting in the second year (1991), two additional FTEs will provide: a) training workshops for teachers; b) presentation of classroom programs; and c) revi- sion, preparation and distribution of curricula. These two FTEs will be employed by Metro and King County. HHW Collection Component The HHW collection component will feature several collection programs that, when combined, provide an efficient and 'FTE stands for "full-time equivalent." A staffing level of "one FTE" could indicate one, full-time, dedicated staff, or it could indicate that several staff spend a portion of their time on a particular task, but that the total effort is equivalent to one full-time staff position. This concept is used throughout the Plan to describe staffing levels. 'The expanded Hazards Line will also serve SQGs; see description under SQG Education and Technical Assistance Component. 1 r. N 3 PLAN DESCRIPTION 3-12 HHW Collection Program Elements convenient collection service for residents in all areas of King County. These services will give the public a way to dispose of HHW properly. The use of both mobile and permanent facilities will provide on-going services for King County residents living in densely populated areas and scheduled drop- off services for those in rural King County. In addition, collection and recycling of specific wastes such as used motor sit oil, latex paint and batteries will be explored, and where feasible, implemented on a large scale. .rt The HHW Collection Component will be managed by a half- time staff person from King County and a half-time staff person from Seattle, who will share a full-time collection coordinator position. A job description for the collection coordinator can be found in Appendix B. .r The collection component costs gradually increase over the twenty years reflecting the increase in service and amount of waste collected. Program costs are $1.28 million in 1990, and $3.27 million in 1994 increasing to $7.7 million in 2009. Disposal costs are figured at $1300 per ton of waste.` HHW Permanent Collection Facilities will be open year round in fixed locations for householders to take their hazardous wastes for proper disposal. Six permanent facilities will be sited for easy access to major population centers (within ten miles); these facilities have the capacity to respond to a large consumer demand. The level of service (hours per week of operation) will be continually increased to accommodate the "r projected increase in waste to be collected. The Plan suggests that one permanent facility come on-line each year, beginning in 1990. Seattle has one operating permanent collection facility located at its South Transfer Station. A second facility is expected to open in north Seattle in 1990. Metro is providing capital funding for construction of °In the Draft Plan, disposal costs were estimated at $1050 per ton. Experience at Seattle's HHW Collection Facility at the South Transfer Station indicated that this estimate ri was too low. In the Final Plan, the estimated per ton disposal cost has been increased to $1300 to reflect actual experience. .r s 111 SECTION 3 PLAN DESCRIPTION 3-13 this facility. These two facilities will be operated by Seattle. The other four permanent collection facilities proposed in the program will be located elsewhere in King County, in either incorporated or unincorporated areas. Suburban jurisdictions could establish and operate permanent collection facilities with funding from the Plan. Meeting this aggressive schedule will depend on several factors, including facility siting and permitting. The intent is to provide convenient collection services for the maximum number of County residents, as quickly as possible. The facilities themselves will appearance, yet will meet all requirements (Figure 3-4). be simple and unobtrusive in applicable health and safety HHW Mobile Collection Facilities will operate for a set period of time -- a few weeks or a month -- in one location, then be moved to other scheduled sites. These units will provide col- lection service at regular intervals to areas of the county not yet served by permanent facilities. The service experience of these mobile units will be used to determine community collec- tion needs and the most appropriate areas for permanent facili- ties. King County will have one mobile facility in operation during 1990, a second in 1991 and a third in 1992. The County will contract for the ongoing operation of these facili- ties and coordinate scheduling with suburban communities. The budgets for these program elements are based on data from the existing facility at the South Transfer Station and preliminary estimates from the first mobile facility being developed by King County. Capital costs for permanent facilities are estimated at $106,000 per facility, while mobile units cost an estimated $33,000 to establish. The total disposal cost for this component is based on the desired amount of waste to be collected. This amount will increase over time as new facilities become operational. The level of service at each facility will also increase over time to respond to an expected rising demand for services as public awareness increases with Plan implementation. If attendance far exceeds expectations, and disposal costs threaten to exceed available funds, implementing agencies will .. be able to control the amount of waste collected by controlling hours of operation. Such a situation would indicate a need for no SECTION 3 PLAN DESCRIPTION 3-14 qf- ell y�� r c � •_._ G � ,.mart �,�r"~`r'!�^L,r�p G- Figure 3-4. PERMANENT HHW COLLECTION FACILITY 1 1 No SECTION 3 PLAN DESCRIPTION 3-15 budget revisions and a management -level decision about whether to increase funding levels. " The intent of the Plan is to allow flexibility in facility design, as long as the overall level of service is achieved and costs remain within the budgeted amount. For example, the City of Bellevue has been sponsoring a 6 -month pilot collection pro- gram for its residents. In this program, a temporary facility collects HHW from the public at a particular location two .. Saturdays each month. Conceptually, this program is some- where between a Round -up and a mobile facility. A program of this design could potentially be continued under the Plan, although it is not exactly like either the mobile or permanent facilities described here, since it provides a level of con- venience and accessibility similar to that which the Plan is proposing to achieve. M Targeted Waste Collection/Recycling In addition, evaluation of the collection program may show that the level of service is adequate with fewer than six permanent and three mobile facilities, or that more are necessary. HHW Pickup Service for the Homebound will help meet the needs of residents unable to get to a collection site. The cooperation of volunteer groups who assist the elderly or homebound will be enlisted. The HHW Collection program coordinator will encourage these volunteers to assist their clients to remove HHW from their homes by bringing these items to a convenient collection facility. The volunteers will distribute information on product substitution and waste reduction practices. This service could also be offered through HHW Education Component waste reduction program elements, such as the Hazards Free Neighborhood (Appendix A). The Plan's diversion goals assume that approximately 38 percent of HHW may be recycled, and that a relatively small portion (18 percent) will need to be incinerated or otherwise disposed of as a hazardous waste, when recycling programs are fully implemented. The Plan contains $200,000 per year for special collection and/or recycling of the targeted wastes listed below and others as they may be identified in the future. These programs will be carried out by a number of jurisdic- SECTION 3 PLAN DESCRIPTION 3-16 i tions. Because many recycling programs are in the very early stages of development, estimating program costs was not possible; the costs in Table 3-2 reflect a commitment to pursue these programs, rather than an accurate estimate of their cost. aw Collection of Used Oil. Seattle will be evaluating the effec- tiveness and feasibility of special oil collection programs, such no as curbside pick-up or neighborhood drop-off facilities, during the first year or two of Plan implementation. Future implementation will depend on the results of this evaluation. as Auto and Marine Battery Collection and Recvcling. Local programs will be developed to implement a new state law requiring a deposit on all lead/acid batteries when Ecology promulgates specific regulations for this law. Household Battery Collection. Collection and recycling of household batteries at the point of sale is possible. For M example, bins could be provided for battery drop-off at convenient locations such as shopping malls, hardware stores and camera stores. Batteries collected in this manner or through collection facilities will be sent to a recycling facility by contracted hazardous waste handlers or sponsoring agency. Paint Recycling. A large percentage of the HHW collected to date is latex paint. Seattle is conducting studies to determine if recycling and treatment is a viable option for latex paint. If feasible, the latex paint will be recycled rather than disposed of as a hazardous waste. These studies will also evaluate the chemical composition of latex paints for hazardous components. Potentially some latex paint can be disposed of in the munici- pal solid waste stream with no adverse environmental effect. In the future, it may also be possible to recycle certain components of solvent -based paint. Promotion of Collection Programs. The HHW Collection Coordinators will be responsible for ensuring that collection facilities and activities are adequately advertised. Promotional materials will have two focuses: to inform County residents about all programs, as well as about the programs in their vicinity. Special promotional activities will support targeted waste collection and recycling programs. rl so No SECTION 3 PLAN DESCRIPTION 3-17 I 11 Education and technical assistance are emphasized over compliance in the management of SQG hazardous wastes under this Plan. An SQG education program coordinator, based at Metro, will be responsible for implementation of this component. Costs for the SQG Education ponent range from $758,000 i 1994, to $1.2 million thereafter. and Technical Assistance com- n 1990, $1.3 million in 1992- SOG Education and Technical Assistance Component The SQG Education and Technical Assistance Component has two focuses, in response to the needs identified by SQGs (Section 2). Programs in this component will fill the information gap concerning waste management techniques and regulations in three ways: TREAT YOUR WASTE Information will be collected and made available to FAIR! SQGs through outreach programs; • New waste management technologies will be tested and perhaps developed locally; • Technical assistance, in the form of laboratory resources and on-site consultations will be made available to individual, interested SQGs. The success of these programs will depend on a close and Positive working relationship between sponsoring agencies and - businesses and trade associations. For the purposes of the Plan, it is assumed that there are approximately 20,000 businesses in King County that are also SQGs (see Appendix B). These 20,000 businesses must be distinguished from the thousands of businesses that are either regulated generators or that generate no hazardous waste. Over the life of the Plan, many more businesses than this will need to be contacted, since many SQGs will go out of business and many new SQGs will open. I 11 Education and technical assistance are emphasized over compliance in the management of SQG hazardous wastes under this Plan. An SQG education program coordinator, based at Metro, will be responsible for implementation of this component. Costs for the SQG Education ponent range from $758,000 i 1994, to $1.2 million thereafter. and Technical Assistance com- n 1990, $1.3 million in 1992- 7' SECTION 3 PLAN DESCRIPTION 3-18 SQG Education " Program Elements Information Development and Resources includes creation and • distribution of educational materials such as newsletters, brochures and fact sheets. Printed materials will be distributed to businesses in King County via mailings, collection site promotions, seminars and workshops. Seminars and workshops TREAT YOUR will focus on the needs of specific industries. Metro will WASTE assume responsibility for this program, although other jurisdic- ar FAIR! tions could participate. One full-time and one half-time staff will be dedicated to it. r An SQG Resource Library, housed at Metro, will obtain and make available materials and case studies on proven hazardous waste management techniques. The library could operate as a ,r branch of Ecology's Technical Resource Center for SQGs. Materials available nationally will be obtained from the state- sponsored Technical Resource Center, while the local library will supplement this collection with local resources and materials. The program will include a computerized data base. One full-time staff will be dedicated to the program. The SQG Telephone Information Line, part of the Health -: Department's Hazards Line, will provide a source of compre- hensive information on hazardous waste issues including regulations, product alternatives, information from manufac- o 0 0 turers on new products or treatment technologies, disposal 0 0 0 options, and any other topic of concern. The equivalent of one ' �•' staff person will be added to the Hazards Line staff to respond � to SQG questions. This program could also serve as a primary mechanism for the dissemination of SQG hazardous waste in- formation materials developed under the Information Develop- ment and Resources program. The Hazards Line will be equipped with a computer to take advantage of on-line information from the Resource Library. The Health Department will also sponsor an SQG Passive Waste Exchange to facilitate the transfer of wastes from the generator to a party that can use them. The Health Depart- ment has already begun a passive waste exchange called, "IMEX", or the "Industrial Materials Exchange." One and a half FTEs currently work in the program. Under this program, the Health Department is in contact with businesses with information concerning usable wastes. A description of the ■rt 19 M SECTION 3 PLAN DESCRIPTION 3-19 waste listed with IMEX is entered on a computer and made available through a bi-monthly catalog. The Health Depart- ment does not handle or transport any wastes during the exchange process. Technical Assistance fflffProgram Elements Metro will promote SSQQ Waste Reduction. Recycling and Treatment, by encouraging the development and use of waste reduction processes or technologies by businesses, through loans, grants and awards. A technology transfer program will •. provide a means of information exchange between the developers of new technologies and businesses interested in waste reduction. An internship program will involve students ,., in technology development and transfer. One full-time staff will be responsible for coordinating these activities. M M 17 On-site Consultation Service staff will visit businesses, at their request, to help them improve hazardous waste management practices. Staff will review current practices and recommend ways to reduce waste, given the business' available resources. This program will not be associated with any compliance activities, such as the Surveys and Audits program. The on- site consultation service will be based at Metro and will require a coordinator and two field staff brought on in 1990, gradually increasing to four by 1992. The number of busi- nesses contacted in 1990 is expected to be 120, increasing to 300 in the following years as the program becomes fully staffed and field personnel become more efficient and know- ledgeable about SQG waste management practices. At the end of the twenty-year program, approximately 6000 businesses will have obtained voluntary on-site consultation services. The SOG Waste Characterization and Treatment Feasibility Program will test the feasibility of treating hazardous wastes prior to disposal and will develop prototype waste profiles for certain SQG waste streams. The waste characterization pro- gram will have three full-time dedicated staff and funding for testing equipment. Since this program involves laboratory testing, it will be based at Metro's environmental laboratory. SECTION 3 SQQ Collection Component SQG Collection Program Elements PLAN DESCRIPTION 3-20 To date, few economical disposal options have been open to SQGs. The Plan recognizes that more accessible SQG collec- tion services are needed. Localovernments will encourage brokers and licensed treat- ment, storage and disposal companies (TSDs) to serve the SQG market by allocating resources to contracted SQG collection programs in the early years of the Plan. This will provide an incentive for TSDs or brokers to establish dedicated SQG col- lection services by decreasing the financial risks associated with this kind of expansion. Once the collection programs are ■ set up and running, it is anticipated that private industry will assume full operation. Two types of services, mobile and auxiliary facilities, are recommended. A disposal subsidy program is also offered to ease the economic burden of hazardous waste disposal for qualified SQGs. Costs for the SQG collection component range from $381,000 in 1990, to $940,000 in 1994. The program phases out completely in 1997. Total cost for this component is $5.1 million over the life of the Plan or about three percent of total cumulative Plan costs. This component will be coordinated by one full-time staff based at King County, who will develop Requests for Proposals for the collection sites, manage the contracts, and oversee the subsidy program. This position will be phased out when the private sector assumes responsibility for the collection pro- grams and the subsidy ends. .r .r Mobile Collection Facilities will be set up for a short period of , time in a given location and will then move to other locations. One mobile facility will be in operation by the end of 1990; a second will come on line in 1992. Government support will be phased out after five years for each facility, at which point the facilities will be run by private companies. Auxiliary Collection Facilities will serve businesses located in areas of the county where fewer TSD services are available, for example, north King County. Two collection sites will be 0 e M M SECTION 3 PLAN DESCRIPTION 3-21 r established in areas that do not have convenient access to TSD facilities. It is expected that these facilities will be established in 1991 and 1993. As with the mobile facilities, government support of this program will be phased out after five years for each facility when the private sector assumes responsibility. These programs are highly experimental and their success will be based on a variety of factors, including interest of the private sector in taking on the program, the ability to site .. facilities, and the willingness of businesses to use them. To encourage businesses to use these and other disposal and recycling options, a subsidy program is proposed. r Compliance Component The SQQ Subsidized Collection Program will cover 25 percent of the disposal costs for SQGs that participate in the On-site Consultation program- or the Survey and Audit program (described below). The status of the business as an SQG must be confirmed in order for the business to receive the discount. The subsidy will begin in 1991, after a feasibility study in 1990 to determine the best way of distributing the funds. The budget for this program is an estimate. The feasibility study will develop more accurate cost projections based on specific program design. The program will run for five years, after which SQGs will become entirely responsible for the costs of hazardous waste management. Providing a subsidy in the early years of the program will help overcome the primary barrier to effective hazardous waste management -- cost to individual businesses. It is expected that once businesses are brought into the education and compliance network, with the help of the subsidy, they will continue to manage their wastes responsibly. The compliance component has two focuses. The first is to clarify and strengthen the regulatory framework for HHW and SQG waste disposal. The second is to strengthen the ability of local governments to identify SQGs and bring them into com- pliance with local environmental regulations. Programs under this component emphasize interagency cooperation and the establishment of a formal mechanism to track inspections and compliance actions. Finally, if businesses do not comply with regulations, enforcement steps will be taken. I ;ECTION 3 PLAN DESCRIPTION 3-22 Compliance Program Elements A compliance coordinator, based at Metro, will facilitate interagency activities and is responsible for ensuring implementation of compliance programs. Total costs for the compliance component will be $650,000 in 1990, rising to $1.0 million in 1994 and remaining at about $1.3 million per year thereafter. .r Enhancement of Local Ordinances. A few specific, identified local ordinances prohibiting the disposal of HHW and SQG No hazardous wastes in the solid and liquid waste streams will be reviewed and strengthened (Appendix A). The purpose of this effort is to clearly define SQG and HHW management require- .r ments and to make these requirements consistent across local jurisdictions in King County. Interagency Re ug latory Analysis Committee (IRAC-1. A com- mittee of local and state agency representatives will review and update local regulations pertaining to HHW and SQG wastes to ensure a consistent regulatory framework across the region. Initially, the committee will survey and analyze existing hazardous waste regulations of all agencies and cities in King County to identify gaps and overlaps and to recommend a co- hesive and comprehensive regulatory network for SQGs and households. IRAC will expand on the work done under the Enhancement of Local Ordinances program and will provide a mechanism for local governments to monitor state and federal regulatory actions in relevant areas. Both the Enhancement of Local Ordinances and the IRAC will require designating staff at the level 0.1 FTE annually from each of ten participating agencies. The enhancement of local ordinances effort should be complete and phased out after five years. The compliance coordinator will provide administrative support for the committee. Committee members will be responsible for overseeing proposed regulatory changes through the appropriate processes in their own jurisdictions. The SOG Survey and Audit Program will enable trained staff to visit SQGs in King County to: a) obtain information about ' waste quantities, types and management practices; b) L SECTION 3 PLAN DESCRIPTION 3-23 The Response Network will be an interagency system to com- prehensively address hazardous waste concerns and incidents. Under this program, a central coordinating office or function will be established in Metro, and a standardized inspection checklist developed. Field staff from various compliance agencies, such as fire or building departments, will be trained to identify hazardous waste management problems in the course of their routine inspections. Problems identified will be noted on the standardized checklist and referred to Response Network follow-up staff or to the appropriate regulatory agency. The Response Network will also investigate complaints from the public. disseminate information, identify problems and solutions; and, c) when necessary, institute compliance proceedings. Metro will sponsor the survey program. Surveys target all businesses in a defined geographic area to identify businesses that might have waste management problems. Each full-time staff assigned to this program is expected to identify approxi- mately 100 SQGs each year from the businesses surveyed. One full-time staff will be dedicated to this program in 1990, n increasing to six by 1995. Over the life of the Plan 10,500 SQGs could be identified and contacted through surveys. AUDIT kin- -� ar The Health Department will sponsor the audit program. Audits .Y W.YI.• ... w �... target specific industries for an in-depth analysis of waste "" "" "" Gr management practices; it is estimated that each full-time staff person in this program could audit 100 SQGs per year. The purpose of an audit is to identify ways to solve waste manage- ment problems. Three field staff will be assigned to the audit program in 1990, increasing gradually to 12 by 1999. Over the life of the Plan, as many as 35,000 SQGs could be audited, enabling the program to keep pace with economic growth and new business formation. Coordination with exist- ing audit programs of solid waste or other agencies will be a priority. An SQG identified through a survey or audit may choose to take advantage of the on-site consultation program for more in - 6 depth assistance with waste management. The primary purpose of the Survey and Audit program, however, is to help local F governments identify businesses that do not participate in education activities or otherwise seek out waste management information. The Response Network will be an interagency system to com- prehensively address hazardous waste concerns and incidents. Under this program, a central coordinating office or function will be established in Metro, and a standardized inspection checklist developed. Field staff from various compliance agencies, such as fire or building departments, will be trained to identify hazardous waste management problems in the course of their routine inspections. Problems identified will be noted on the standardized checklist and referred to Response Network follow-up staff or to the appropriate regulatory agency. The Response Network will also investigate complaints from the public. M SECTION 3 PLAN DESCRIPTION 3-24 M Evaluation Component The Response Network will be coordinated by one full-time staff in 1990 and a second in 1991. In addition to existing agency field staff, up to four full-time staff with enforcement authority will conduct follow up inspections; one field staff will be brought on each year from 1990 to 1993. Field staff could work with up to 75 businesses each year. Over the life of the Plan, approximately 5500 businesses will be visited by Response Network staff. The coordinators and the additional field staff will be based at Metro; existing field staff in a variety of agencies, such as the Health Department, Fire r Departments and others, will participate in the Network. The Network could also serve as the hub of the SQG educa- tion and technical assistance and compliance programs. The survey and audit programs could use it to provide necessary interagency coordination. Field staff from these programs .. would also use the standardized inspection checklist and refer problems outside their authority to the Response Network for follow-up. The state guidelines require that the Plan include a process for updating and revision every five years. Given that many of the programs included in the Plan are new, an extensive evalu- ation program is planned. Evaluations will determine how well the programs are being implemented and whether the objectives of the Plan are being achieved. Based on this evaluation, revi- sions may be necessary within the five-year planning period. As part of the Plan update, new programs may be proposed. Evaluation needs to occur on several levels. Evaluation of individual programs implemented under the Plan is crucial, since many of the programs included in the Plan are new and untried and the success or failure of these programs will guide the Plan update and revision process. The overall effectiveness of Plan implementation must also be evaluated. The success of this Plan will require a fundamental change in consumer awareness and business practices. The ability to do this well depends partly on careful monitoring and the flexibility to change course, if necessary. Finally, cost-effectiveness of the programs must be evaluated, to ensure that programs are efficiently carried out. 0" e M M SECTION 3 PLAN DESCRIPTION 3-25 A number of evaluation tools can be applied. These include the use of surveys and opinion polls of various kinds, such as telephone surveys and interviews. Waste sorts and water quality sampling can give a measure of the amount of hazard- ous waste entering these two waste streams. Audits of busi- nesses can measure what percentage of businesses are dis- posing of their waste properly, and evaluate business waste management practices. In the first year of Plan implementation, an evaluation strategy will be developed for all components of the Plan, including identification of data collection needs for each program area. The evaluation strategy will include monitoring levels of hazardous waste in the municipal solid and liquid waste stream over time to detect any changes that may be attributable to the Plan. Evaluation will also include periodic assessment of public awareness and changes in behavior with regard to the use of hazardous household products. In addition, every program will include collection of data relevant to the overall Plan evaluation strategy. I u 1 J D D Evaluation of the HHW collection programs will include measures of: the amount of waste collected, the number of participants, costs of the programs, and customer satisfaction. The evaluation will compare the different collection options -- permanent sites and mobile facilities -- as they come on-line. The effectiveness of publicity and educational activities on participation rates will also be measured. The SQG collection programs will also be evaluated. All of these programs require only a short-term public sector commit- ment. One crucial measure of success will be the willingness of the private sector to assume responsibility for the collection programs at the end of that period. In any case, data similar to the HHW collection program evaluation will be collected and analyzed. At a minimum, these data will contribute a great deal to an overall characterization of SQG wastes, which will be useful for information dissemination and technical assistance programs. The effectiveness of both the HHW education programs and the SQG education and technical assistance programs in encouraging waste reduction and proper disposal will also be evaluated. The number of people or businesses reached is one indicator of activity, but there will also be an attempt to rir SECTION 3 PLAN DESCRIPTION 3-26 M PLAN FINANCING AND IMPLEMENTATION measure changes in behavior. An indication of behavioral changes may be obtained through a series of attitude surveys over time, as well as through participation rates at collection sites. Changes in behavior of businesses can be measured through follow-up visits after audits, for example. Some of the SQG technical assistance programs and the SQG collection programs are intended to remove financial or other barriers to proper disposal of SQG wastes. One indicator of success in this area will be increased disposal of SQG waste •r either through the Plan's collection programs or existing TSD facilities. M Because evaluation is integral to the entire Plan, all agencies will have a role to play in the evaluation process. The Man- agement Coordination Committee (described on page 3-38) will be responsible for establishing program objectives and goals for evaluation. The Committee will review and approve evaluation reports, and make program recommendations for the following year(s). A staff -level committee, (described on page 3-38), composed primarily of Program Coordinators will establish evaluation methodology and criteria, direct evaluations, and review evaluation reports prior to submittal to the Management Coordination Committee. The evaluation coordinator position will be one FTE divided between the Health Department, the City of Seattle Office for Long-range Planning and Metro. The evaluation coordinators would propose evaluation design, identify data collection needs, and manage the evaluation contracts. Evaluation results would be summarized in periodic (annual) reports to the Management Coordination Committee. Much of the actual evaluation would be done through con- tracts. The coordinators would facilitate the collection of overall baseline data. Work products would be reviewed by the staff committee and the Management Coordination Committee. Costs of the evaluation component range from $140,000 in 1990 to $125,000 in 1994. Several options for financing and implementing the Plan were so presented in the Draft Plan/EIS. These options are summarized W Ed M M M be im M M F7 SECTION 3 PLAN DESCRIPTION 3-27 Financing State Funding in Table 3-4. Based on public comment and input from local governments, a financing and implementation strategy has been developed. This strategy assures that sufficient funding will be available, and that participating jurisdictions will be able to work together to implement a regional hazardous waste management plan. The Draft Plan/EIS described several options for financing including state funding through use of the state hazardous substance tax, a local add-on to that tax, and local funding through utility rates or assessment of municipalities, as well as user fees. These options were not all exclusive of each other, and the final Plan assumes several of these sources will finance the total cost of implementation. The level of financing described below is sufficient to fund the estimated cost of the Plan as summarized in Table 3-2. The constraining factor is the estimate of the overall program cost. If actual costs for some projects prove to be higher, expenditures for other projects will have to be adjusted to maintain the same program cost level. Funding from the state hazardous substances tax is considered important for several reasons. First, a tax on hazardous substances is seen by reviewers and respondents as the most equitable way of funding the Plan because it places the burden directly or indirectly on those using hazardous products. Charging users for management and disposal of hazardous waste better reflects the true cost of these materials. In fact, many people wanted consumers to know the amount of tax they would be paying since that would help educate them to perhaps reduce their use of such products. Fifty-three percent of the revenue generated under the state hazardous substances tax (Initiative 97, passed November, 1988) will be deposited in a "Local Toxics Control Account" (LTCA). Hazardous waste plans and programs are one of the funding priorities for this account. It is felt that funding of plan implementation is an appropriate use of the LTCA. Local SECTION 3 PLAN DESCRIPTION 3-28 Table 3-4. FINANCING AND IMPLEMENTATION STRATEGIES SUGGESTED IN THE DRAFT PLAN' Financing State Funding • Local Toxics Control Account • King County Add-on to the State Hazardous Substances Tax Local Share • Sewer Utility Rate Increase • Solid Waste Tipping Fee Increase • Board of Health Fee Increase for Solid Waste Haulers • Assessment of Municipalities • User Fees, Permit Fees, Fines Implementation • Voluntary Implementation • Interlocal Agreement • Hazardous Waste Management Committee • Lead Agency 'The information in this table is presented for review purposes only. The final Plan .o financing and implementation strategy incorporates several, but not all, of these options. go M r r M M W M SECTION 3 PLAN DESCRIPTION 3-29 governments feel that the state has a responsibility to help fund programs it requires local government to implement. Finally, state funding is considered to be a financial necessity. Full implementation of all the programs in this Plan will not be possible without state funds. Estimated Level of State Funding. In the Draft Plan, it was estimated that the Local Toxics Control Account would collect $14.8 million in 1990. If 20 percent, or $3 million, of the Account were allocated to hazardous waste plans and programs and if King County were to receive an amount proportional to its population, King County would receive an estimated $920,000 annually. •• Ecology has since reduced its estimate of the LTCA allocation. Based on conversations with Ecology staff, it has been esti- mated that approximately $3.8 million will be available in the .r 1990-91 biennium for hazardous waste plans and programs, or $1.9 million each year. Assuming King County were to re- ceive an amount proportional to its population, state funding would be approximately $590,000 for each of 1990 and 1991. ' In addition, Ecology is also considering revisions to the hazardous waste fees charged generators of hazardous waste in compliance with Section 16 of Initiative 97. Money collected ' from such fees could be used to support implementation of local hazardous waste management plans. Table 3-5 summarizes funding sources, assuming this level of state funding for 1990 and 1991. ' For the years beyond 1991, estimating state funding levels becomes even more difficult. If the growth rates used by the Legislature for the LTCA are applied, assuming the same proportionate amount for hazardous waste plans and programs, ' the funding levels would be as shown in Table 3-5. Ecology is in the process of developing the regulations gover- ning the allocation of these grant funds. A waste management "block grant" approach is being considered. That approach is desirable since it would give local governments some way of ' anticipating a certain level of state support. It would also greatly cut down on paperwork and administrative overhead. r SECTION 3 PLAN DESCRIPTION 3-30 Table 3-5. FUNDING ALLOCATIONS` 1990-1994 (dollars in thousands) Total Program Cost State Funding Local Funding Sewerage Agencies Solid Waste 'in 1989 dollars 1990 1991 1992 1993 1994 $3,742 5,202 6,268 7,107 7,871 590 590 728 728 869 3,152 4,612 5,540 6,379 7,002 630 922 1,108 1,276 1,400 2,522 3,690 4,432 5,103 5,602 go r SECTION 3 PLAN DESCRIPTION 3-31 For purposes of this Plan, a block grant approach has been assumed, allocated based on percentage of population. If state funding does not meet the estimates shown here, program funding levels will have to be reduced accordingly. In 1990 and 1991, this would mean a reduction of $590,000 per year. Approximately $300,000 of each year's reduction would come from the household programs and $290,000 from the SQG programs. For the household programs this cut would be achieved by limiting or delaying the initiation of certain projects. Candidates for reduction include the school programs and waste reduction programs. Another option would be to put off development of a third permanent collection facility, or to cut • back the hours of existing facilities. A combination of these options could be used to obtain a reduction of $300,000. r. For the SQG programs, most of the reduction could be ob- tained by reducing or phasing in more slowly the technical assistance programs, such as the waste characterization and „ treatment effort, and some of the information development and resources programs. Some of these programs could be left for Ecology to implement directly. Another option would be to .. phase in more slowly the compliance programs, allowing edu- cation and technical assistance programs to have an impact before compliance programs are initiated. ~ With these program reductions, the Plan would still meet all Ecology guidelines and would be a fully viable plan. How- ever, the goals for waste diversion would be met more slowly. Local Add-on to the State Hazardous Substance Tax Respondents expressed an interest in using a local add-on to the Hazardous Substance Tax to help fund the Plan, primarily because of the equity issue as described above. Yet, it was recognized that since state legislation would be needed to implement this option, significant lead time would be required and its approval would be uncertain. For that reason, no estimate of funding from this source is included in the Plan. r. However, as part of plan implementation it is recommended M M SECTION 3 PLAN DESCRIPTION Local Funding 3-32 r that this option be pursued in conjunction with other areas in the state that are implementing local plans. Even if state funding is obtained, local funds will be a major financing source for plan implementation. It is recommended that fees be assessed on certificated solid waste haulers, on "self -haulers" using the transfer stations or landfill, and on sewage treatment facilities. The fees would be set by the King County Board of Health and the Seattle City Council', and collected on a quarterly basis by the Seattle King -County Health Department. The cost of implementing the Plan was divided between solid waste and sewage sources based on the proportion of HHW so and SQG waste received by each. It was estimated that 15 to 20 percent by weight of HHW and SQG wastes is discharged into the sewerage system, and the remaining 80 .to 85 percent ••+ is disposed of in the solid waste system. Therefore, for financing purposes, 20 percent of the local funding for the Plan is suggested to come from fees on sewage treatment facilities .rr and 80 percent from solid waste haulers. The solid waste portion is proposed to be funded as follows: „r 1) "Certificated" haulers (subject to regulation by the Washington Utilities and Transportation Commission) and haulers under contract to cities where the haulers bill their customers directly will be assessed a per account fee by the King County Board of Health. Haulers of commercial garbage in Seattle will be asses- sed this fee through the Seattle City Council acting as the City of Seattle Board of Health. One fee will apply to residential accounts, and a different fee will apply to commercial accounts. In this way, residential customers will only pay for the household portion of the plan and commercial customers for the SQG portion. r-7 No 'The King County Board of Health has jurisdiction over all of King County, except the City of Seattle. In Seattle, the Seattle City Council is the City's Board of Health. For M„ i; all King County residents to be represented in Plan adoption and implementation, both governing bodies must be involved. Nr R r. SECTION 3 PLAN DESCRIPTION 3-33 on r W Ej The amount to be raised through non -PLV self -haul tonnage shall not exceed 29 percent of the total SQG solid waste contribution, the level of self -hauler contribution to total commercial tonnage. Sewage treatment plant operators serving more than 50 customers will be assessed a fee on a per gallon basis for sewage and septage treated, to capture funding for that portion of HHW and SQG wastes entering the liquid waste stream. Septic tank owners would be charged indirectly by sewer districts or Metro when they pump out their tanks and dispose of the septage at a municipal treatment plant. Funding Rationale. There were several reasons why this funding approach was selected. One reason is to simplify administration. Because the fees will be assessed on utilities, haulers and sewage treatment plants, the Health Department 2) Residential (passenger licensed vehicles or PLVs) "self - haulers" will be charged a per vehicle fee, and commer- cial (non -passenger licensed vehicles) "self -haulers" will be charged a fee per ton of garbage they dispose of at King County transfer stations and rural landfills. These i fees will also be set by a King County Board of Health Mrr I i rule. 3) The Seattle Solid Waste Utility will contribute to the Plan implementation fund a fee authorized through a Seattle City Council ordinance. This payment will be based on a per account fee for each residential account, plus a per ton fee for all non -PLV self -haul garbage disposed of at Seattle transfer stations. 1988 tonnage shall be used as Seattle's base year for calculating the wr 1990 contribution. The Solid Waste Utility rate -setting process will determine how this amount is generated (e.g., by transfer station fees, utility bills, etc.). 4) Other cities that bill garbage customers directly will contribute a per account fee for all the solid waste accounts they handle. The fees assessed on residential accounts and the PLV "self - haul" fee will be used for the HHW program. The fees asses- sed on commercial accounts and per ton fees for non -PLV self -haul will be used for the SQG program. on r W Ej The amount to be raised through non -PLV self -haul tonnage shall not exceed 29 percent of the total SQG solid waste contribution, the level of self -hauler contribution to total commercial tonnage. Sewage treatment plant operators serving more than 50 customers will be assessed a fee on a per gallon basis for sewage and septage treated, to capture funding for that portion of HHW and SQG wastes entering the liquid waste stream. Septic tank owners would be charged indirectly by sewer districts or Metro when they pump out their tanks and dispose of the septage at a municipal treatment plant. Funding Rationale. There were several reasons why this funding approach was selected. One reason is to simplify administration. Because the fees will be assessed on utilities, haulers and sewage treatment plants, the Health Department 1 SECTION 3 PLAN DESCRIPTION 3-34 will have to bill a relatively small number of accounts -- r about 27 haulers, 10 sewerage agencies (including Metro) and about 45 septage haulers for all of King County. This one funding source will provide all the local funds necessary for Plan implementation. Local municipalities will not have to raise funds individually. Thus the problem of obtaining appropriations from 29 different municipalities would be avoided. A second reason for selecting this funding approach is relative equity. Almost all individuals and businesses contribute to some extent to the hazardous waste stream. Certainly the entire King County population benefits from the proper management of these wastes. This broad-based funding source, where almost all King County residences and commercial establishments will make some contribution to the costs of the •r+ program, is therefore viewed as equitable. Most dischargers of hazardous waste would be captured by this .r funding mechanism without the double counting that would result if King County, Metro and the municipalities raised fees independently. Limitations to this approach from an equity standpoint still exist, but they are less significant than the inequities of other mechanisms evaluated. The number of residential and commercial accounts does not translate directly to the number of customers. Although the haulers may equalize any cost that is passed on to all customers, some inequity may still result. Charging all commercial accounts equally does not reflect the fact that some businesses may generate much more hazardous waste than others. Finally, septic tank users, who may have a significant impact on groundwater quality, are only indirectly and infrequently charged for their portion of the sewerage fees. Impacts on Rates. In most areas of the County, customers pay their solid waste fees to garbage haulers directly. Haulers' rates are subject to approval by the Washington State Utilities and Transportation Commission (WUTC). If the haulers elect to pass the fee increase on to their customers, they must ask the WUTC for a rate increase. For cities with solid waste utilities, customers pay rates to the city and the city contracts with garbage haulers for collections. If these utilities elect to pass the fee on to their customers, the city councils would have to act on a rate increase. �► r we us M SECTION 3 PLAN DESCRIPTION 3-35 Metro currently treats over 90 percent of the total volume of wastewater collected in King County. Nine additional indepen- dent cities or sewer districts treat the rest. Twenty percent of the local share of Plan costs will be obtained through fees assessed Metro and these sewer districts. Each district may elect to use existing revenues to cover the fees or to raise rates for its customers. Fee Levels. The level of fees needed to fund the Plan is .. shown on Table 3-6 for solid waste and Table 3-7 for waste- water. This does not include the cost of administering the fees. +. Plan Implementation UW M .. r M W am User Fees. Jurisdictions may also choose to charge a user fee for users of the hazardous waste collection facilities. This would be in addition to and separate from the per vehicle or per ton fee for self -haulers, described above, which all self - haulers would pay. Whether such a fee would affect user behavior, making people less willing to use such facilities and properly dispose of their waste, is an issue that is still un- resolved. This issue will be explored during the evaluation process. However, if a user fee is established, the same fee should apply to all users, and any amount collected through such a fee would be offset against any reimbursable cost for that jurisdiction. The Draft Plan/EIS laid out several options for plan implemen- tation ranging from voluntary implementation with no coordina- tion, to having one lead agency. The selection of the funding mechanism helps define the organizational framework needed for implementing the Plan. If fees are levied through the Health Department, then those fees must be set by the County Board of Health and the Seattle City Council, and some mechanism for distributing the funds must exist. The Plan covers all of King County so it is considered important to have some coordination mechanism to ensure that the objectives of the Plan are being met. Yet at the same time, many respondents wanted to ensure a high degree of flexibility, so that municipalities could if they wanted, design and implement their own programs. Finally, many respondents wanted to avoid the creation of new political entities. SECTION 3 PLAN DESCRIPTION 3-36 Table 3-6. SOLID WASTE FUNDING ALLOCATIONS AND FEES' 1990-1994 (dollars in thousands) HHW Component of Solid Waste Allocation Seattle Contribution ($/account) Certificated Haulers ($/account) PLVs (King County) ($/vehicle) SQG Component of Solid Waste Allocation Certificated Haulers ($/account) Self -Haul at King County Facilities ($/ton) Self -Haul at Seattle Facilities($/ton) 1990 1991 1992 1993 1994 $1,268 1,903 2,313 2,762 3,209 470 706 858 1,024 1,190 (3.36) (5.04) (6.13) (7.31) (8.50) 624 850 934 1,131 1,325 (2.63) (3.58) (3.93) (4.76) (5.58) 174 347 521 607 694 (.50) (1.00) (1.50) (1.75) (2.00) $1,253 1,788 2,120 2,344 2,395 891 1,335 1,576 1,711 1,762 (45.22) (67.77) (80.00) (86.85) (89.44) 287 359 431 502 502 (1.00) (1.25) (1.50) (1.75) (1.75) 75 94 113 131 131 (1.00) (1.25) (1.50) (1.75) (1.75) 'in 1989 dollars. This table is for illustration purposes only. Actual amounts may change. The number of residential accounts for Seattle is estimated at 140,000, and 237,000 for King County. The number of passenger licensed vehicles (PLVs) for King County is estimated at 347,000. The number of commercial accounts is estimated at 19,700. Estimated self -haul tonnage for King County is 287,000 and 75,000 for Seattle. These estimates are held constant over the five years shown although it is recognized that they will need to adjusted on an annual basis. Fees for self -haulers were set to total no more than 29% of the cost of the SQG program, which was the estimated contribution of self -haul to the commercial waste stream. r M No M no .w we .W ad so so .r to we M SECTION 3 PLAN DESCRIPTION 3-37 w Table 3-7. SEWERAGE FUNDING ALLOCATION AND FEES' 1990-1994 (dollars in thousands) 1990 1991 1992 1993 1994 All Sewerage Agencies $630 922 1,108 1,276 1,400 Metro' 565 827 994 1,145 1,256 Annual Increase 0 +262 +167 +151 +111 Affecting Future Metro Rates Approximate Metro 0 +4¢ +3¢ +2¢ +2¢ Rate Impact3 Other SW Suburban 24.0 35.0 42.0 48.0 53.0 Federal Way 20.0 29.0 35.0 40.0 44.0 ■. Midway 14.0 20.0 24.0 28.0 30.0 Enumclaw 4.0 6.0 8.0 9.0 10.0 North Bend 1.0 1.4 1.7 1.9 2.1 ,,.. Duvall 0.8 1.2 1.4 1.7 1.8 S noqualmie 0.7 1.0 1.2 1.4 1.5 Black Diamond 0.4 0.6 0.8 0.9 1.0 V ashon 0.2 0.4 0.4 0.5 0.5 r 'in 1989 dollars. This table is for illustration purposes only. Actual amounts may change. Distribution of sewerage costs is based on 1988 annual average gallons of wastewater treated by all municipal agencies. These figures and relative contributions will change yearly. 2Metro treats 90 percent of the municipal wastewater handled by sewerage agencies in King County. This funding allocation represents approximately 18 percent of the total annual budget for the Plan. 'Sufficient funds are already appropriated in Metro's 1990 budget. Future rate impacts are estimated at $0.16 per million dollars of Metro's share. 'Other sewerage districts or utilities treat 10 percent of the municipal wastewater in King County and will cover approximately 2 percent of the total annual budget for the Plan. 0 up C SECTION 3 PLAN DESCRIPTION 3-38 ' The recommended organizational structure for implementation of the Plan, once it is adopted, will work as follows. To assess the fees, the King County Board of Health will pass a rule and the Seattle City Council will pass an ordinance with • the same effective date. The rule and ordinance will direct the Seattle -King County Health Department to collect the fees on a quarterly basis. The fees will be collected and disbursed in ..� the same fiscal/calendar year, per accounting procedures re- quired by the State. As necessary, the King County Board of Health and the Seattle City Council will reassess fees to ensure .. that sufficient funds are available to implement the program. The rule and ordinance that set the fees will also create an so interagency Management Coordination Committee that will oversee the development of an "annual implementation plan" and budget for disbursement of funds. The committee mem- ■r bership will be composed of senior staff (similar to the Senior Management Committee for Plan development, Appendix A) designated in the rule by position (e.g., Director, City of r Seattle Solid Waste Utility) and will include representation from the major participating government entities, namely King County, the Health Department, City of Seattle, Metro, and the Suburban Cities. "� The committee will recommend an annual plan and budget to the Seattle City Council and King County Board of Health. The Solid Waste Interlocal Forum will be informed of annual implementation plans. The County Board of Health and Seattle City Council will act on this recommendation each year, and the funds will be disbursed by the Health Department following the Council's and Board's action. 1W The Program Coordinators of the six Plan Components will work together in a staff -level committee, and will be responsible for developing the annual plan and budget. Other staff involved in Plan implementation will participate in this staff committee as necessary. The relationship between the King County Board of Health, the Seattle City Council, the Management Coordinating Committee and the staff committee is illustrated in Figure 3-5. so The Health Department will be responsible for disbursing the funds to participating jurisdictions on an annual basis. 10 Disbursement will be accomplished through contracts, .r 40 SECTION 3 PLAN DESCRIPTION 3-39 King CountyII II Seattle City Board of Health Council Management Coordination Committee King City of Metro Seattle -King County Suburban County Seattle Health Department Cities Staff Committee (Program Coordinators) HHW SQG Education Education & Technical Health Assistance Metro HHW Collection Seattle King County Compliance M etro SQG Collection King County Budgets & Contracts Health Evaluation Seattle M etro Health Figure 3-5. PLAN IMPLEMENTATION ORGANIZATIONAL STRUCTURE Membership on the Staff Committee is not limited to the Program Coordinators, but can also include representatives of other agencies implementing program elements. SECTION 3 PLAN DESCRIPTION 3-40 interagency agreements or memoranda of understanding. The Health Department will disburse the funds according to the annual implementation plan as passed by the County Board of Health and the Seattle City Council. Local jurisdiction, including suburban cities as well as Seattle, King County, and Metro will have the opportunity to imple- ment programs directly if they wish. These programs would be included in the annual implementation plans, and the jurisdictions would enter into contracts or agreements as "" described above. They will be reimbursed for their expenses from the Plan fund according to the terms of the agreements. ad Summary The funding and implementation strategy will be approved with Plan adoption. Following this, two concurrent legislative actions will be required: we Plan Adoption 1. The County Board of Health must pass a rule that sets the fees, establishes the interagency Management Com- no mittee, and directs the Health Department to collect and disburse the fees according to an annual plan approved by BOTH the County Board of Health and the Seattle mr City Council. 2. The City Council, acting as the Seattle Board of Health, must pass an ordinance with the same requirements. After 1990: r 1. The Health Department will collect the fees; 2. The Management Coordination Committee and the staff w committee (composed primarily of Program Coor- dinators) will recommend an annual plan and budget; 3. The County Board of Health and the Seattle City Council will amend and/or approve the plan and budget; r 4. The Health Department and participating jurisdictions will enter into contracts or interagency agreements for disbursement of the funds, pursuant to the approved "w annual plan. The procedure for plan adoption should work as follows: King County, Metro and the City of Seattle will each adopt the plan, No .. SECTION 3 PLAN DESCRIPTION 3-41 by action of their respective councils. Adoption by the subur- ban cities will be facilitated by using the Solid Waste Inter- local Forum Plan Approval Process. The Interlocal Forum in- cludes representatives from King County, the City of Seattle, and other incorporated cities and towns in King County. After review and referral of the Plan by the Forum, each suburban city (not including Seattle) would have 120 days to approve or reject the Plan as referred. If approved by municipalities representing 75 percent of the population of those cities which .. have acted within the 120 days, the Plan goes into effect. (The Interlocal Agreement establishing the Forum is included in Appendix B.) Adoption resolutions for the suburban cities (and perhaps larger jurisdictions) could contain language that would permit depart- ments to enter into agreements to implement the plan, such as the following: W Roles of Major Participating Local " Jurisdictions The Executive Director/Mayor/County Executive or designee is authorized to enter into such interagency agreements or memoranda of understanding as may be necessary to conduct said projects, said agreements to be in such as form as may be approved by legal counsel. This would minimize the need for a multitude of ordinances for jurisdictions to accept funds from the Health Department. Agencies participating in Plan development have taken respon- sibility for implementing and operating various programs. These assignments have been made primarily on the basis of legal authority, expertise and willingness. It is expected that all participating local jurisdictions will participate in program evaluation, development of the annual implementation plan and other activities necessary to maintain a regionally -coordinated plan. Specific assignments may change over time, especially if some of the suburban cities wish to be actively involved or responsible for program implementation. r_1 SECTION 3 PLAN DESCRIPTION 3-42 Health Department. The Seattle -King County Department of Public Health will collect and administer the fees, and enter into agreements with other jurisdictions for disbursement of funds. The HHW Education Component Coordinator, the Bud- gets and Contracts Coordinator and a part-time Evaluation Coordinator will be based at the Health Department. In addition to coordinating HHW education programs, the Health Department will be responsible for the HHW and SQG Tele- phone Information Line, the SQG Passive Waste Exchange, and the SQG Audit Program. Metro. Metro will coordinate the SQG Education and Tech- nical Assistance Component, and the Compliance Component. In addition, Metro will share responsibility with the City of Seattle Office for Long-range Planning and the Health Department for the Evaluation Component. Metro will carry we out or coordinate specific program elements, including: SQG Information Development and Resources, SQG Resource Lib- rary, SQG Waste Reduction, Recycling and Treatment, SQG .. Waste Characterization and Treatment Feasibility, the SQG Survey Program and the Response Network. In addition, Metro will participate in the HHW Public Information and „w Outreach program and the Schools Program. King County Solid Waste Division. King County will house one half-time HHW Collection Program Coordinator and one full-time SQG Collection Program Coordinator. The Solid Waste Division will be responsible for the HHW mobile collection program and will participate in the HHW Public r Information and Outreach and coordinate the Schools Programs. City of Seattle Solid Waste Utility. The Solid Waste Utility we will manage two of the six HHW permanent collection sites and participate in the HHW Public Information and Outreach waste reduction programs. One half-time HHW Collection Coordinator will be responsible for the permanent facilities portion of the collection program. In addition, the Solid Waste Utility is exploring targeted waste collection, such as recycling and treatment programs for used oil and latex paints. City of Seattle Office for Long-range Planning. The Office for Long-range Planning will share responsibility for coordinating evaluation with Metro and the Health Department. e M r up Im SECTION 3 PLAN DESCRIPTION 3-43 Suburban cities. The suburban cities will be represented on the Management Coordination Committee by someone appoint- ed by the Suburban Cities Association. In addition, specific jurisdictions may elect to more actively participate in Plan implementation by sponsoring one or more of the Plan's program elements. A suburban city may choose to site a permanent collection facility within its boundaries, undertake an education program, or participate in a survey or audit program of local businesses. Suburban cities that have a significant commercial sector will probably participate in the Response Network, the Enhancement of Local Ordinances Program and the Interagency Regulatory Analysis Committee. Role of Private Sector Participating jurisdictions may elect to administer programs, but instead of having agency staff carry out the work, services .. could be contracted. Many of the education program elements could be carried out by private nonprofit education groups or consulting firms, who would enter into contracts for specific scopes of work with participating jurisdictions. The SQG education programs rely on the voluntary participa- tion of businesses and trade associations. Their involvement will be sought and facilitated by the SQG Education, Collection and Compliance program coordinators. The SQG collection component calls for involvement of the private sector in operating the mobile and satellite collection facilities. HHW collection facilities could also be operated by private firms under contract to local governments. It is ex- pected that private firms will respond to requests for proposals and the winning firms will enter into agreements with the agency responsible for administering these programs. r State Role and r Recommendations for State Action ■• The Washington State Department of Ecology has a critical role to play in ensuring that this plan is fully implemented. .. aw SECTION 3 PLAN DESCRIPTION 3-44 Funding Issues Office of Waste Reduction Role M Funding through the Local Toxics Control Account is essential if all programs are to be carried out as described in this Plan. State programs in the areas of waste reduction, targeted waste programs, and enforcement and compliance are also very im- portant. If local governments are to effectively manage hazardous waste it must be done in partnership with the State. Specific recommendations for state action are described in more detail below. Local Toxics Control Account. Fifty-three percent of the revenue generated under Initiative 97 (passed November, 1988) go will be deposited in the Local Toxics Control Account. Hazardous waste plans and programs are one of the funding priorities for this account. Once the local hazardous waste .r management plans have been completed and approved, state funding support will be critical for their effective implementa- tion. Ecology should devote a certain minimum percentage of .rW that account to hazardous waste plans and programs, to be al- located to localities based on population or some measure of the amount of waste generated. This way, local governments would be assured a certain level of state support. The Plan assumes $590,000 state funding in 1990, rising to $870,000 by 1994. Local Add-on Tax. Local governments should be permitted to supplement the state hazardous substances tax through a local .r add-on tax. Such a tax is an equitable means of funding hazardous waste programs, because it places the burden on those using hazardous products. Charging users of hazardous products for the cost of management and disposal of hazardous waste better reflects the true cost of such products. Ecology, working with local governments, should propose such legislation at the next legislative session. Ecology's Office for Waste Reduction should expand its SQG programs, and these programs should have a local focus. At this time, most of its programs are focused on regulated hazardous waste generators. Some of the programs that should be implemented by the Office for Waste Reduction include: r M M SECTION 3 PLAN DESCRIPTION 3-45 • Consultation services based throughout the state so that they are accessible to the businesses that need advice. Information specific to the needs of SQGs should be developed. • An information referral service and hotline. The pilot Resource Library sponsored by Ecology should be continued. �+ A research and development program that would evalu- ate treatment technologies and promote technology transfer. Technologies applicable to SQG waste streams would be examined along with those for larger generators of hazardous waste. wo Targeted Waste The state should dedicate resources to implement and enforce the Oil Recycling Signage Law. Retailers that sell motor oil are required to post signs informing consumers of the location of recycling depots. This law should be enforced, and Ecology should keep updated lists of oil recyclers for retailers' use. This is especially critical now, since many smaller gas stations are no longer accepting used motor oil. The Legislature has passed a refund deposit program for lead- .. acid auto, motorcycle and boat batteries. All retailers of batteries are required to accept old batteries for recycling. Currently only half of the stores in Washington that sell batteries accept them back. Ecology should promulgate on implementing regulations as quickly as possible. Product Labeling M New legislation passed in the 1989 legislative session modifies Ecology's "Environmental Awards Program". The new pro- gram is modeled on a Canadian program. Safe, nonhazardous products can receive the award, which can be displayed on the product label. Unlike the original program, the award could be displayed for more than one year, making it more attractive to manufacturers. Ecology should move aggressively to imple- ment this program. This program could be a primary means of consumer education and encouraging waste reduction. SECTION 3 PLAN -4 DESCRIPTION 1 3 6 Amnesty Program "w Compliance Current law requires that any business wishing to dispose of 220 pounds or more of hazardous waste be registered with the state as a regulated hazardous waste generator. Many SQGs may be generally aware that hazardous waste should be hand- led "differently" but are unsure what to do with it, and can .r unknowingly exceed the accumulation limits. Under an amnes- ty program, SQGs could be granted a one-time grace period allowing them to dispose of accumulated waste without en- .• forcement penalties. Ecology should establish such a program. 1W Although the Plan stresses education, compliance is still an 00 important component of a comprehensive program. SQGs are only conditionally exempted from the requirements of the State Hazardous Waste Management Act. It will be necessary to rely on Ecology for support for some businesses that are un- willing to correctly manage their waste, if local ordinances are not sufficient. Ecology should be a participant in the Response Network, and provide compliance support where necessary. we to I* .r M Ni A A A I 0 irr ,r SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-1 IMPACTS AND MITIGATION MEASURES The previous chapter of this document describes the Plan to manage small quantities of hazardous waste within King County. The Plan consists of six primary components for local hazardous waste management: HHW education, HHW collec- tion, SQG education and technical assistance, SQG waste collection, compliance with local, State and Federal regulations, and program evaluation. This section will provide information on the potential environmental impacts and consequences of implementing the Plan, as is required by the State Environmental Policy Act (SEPA). Measures to mitigate or minimize potential adverse impacts will also be presented. The Plan is a set of strategies that are not site specific. Therefore, the environmental analysis of the Plan addresses the .. general categories of impacts and mitigation that can be identified at this time. Site-specific environmental review will occur when specific projects with impacts are implemented after the plan is adopted. M e Potentially affected environmental areas to be discussed in this environmental review include: water quality, earth, environmental health (worker and public safety), land use, drainage, and transportation. WATER QUALITY IMPACTS: THE PLAN AS MITIGATION Through current waste management practices, HHW and SQG waste can be discharged into surface waters or migrate to groundwater. This can occur through direct discharges to storm drains, surface water bodies (streams, lakes), the ground, and through uncontrolled landfill leachate and effluent discharged by sewage treatment plants. Generally, the Plan will have a positive effect on the environ- ment, particularly water quality. It is difficult to quantify the amount of HHW and SQG wastes currently entering the ground or surface waters, as the occurrences are dispersed in time and space. However, local examples exist of cumulative SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-2 IMPACTS AND MITIGATION MEASURES no environmental impacts resulting from inappropriate disposal practices. In recent years, some local municipal landfills have been iden- tified as sources of contamination. In some of the cases, the landfills have been designated Superfund sites under the "" Comprehensive Environmental Response, Compliance and Liability Act (CERCLA). ■r Years of receiving hazardous wastes from industry, SQGs and households created critical conditions at the City of Tacoma Landfill. The cost of closing this facility has been increased an due to extensive environmental contamination. The landfill closing requires a groundwater pumping and treatment program to restore the quality of the City's drinking water source. The .. initial cost of this program is estimated at $3 million, with costs continuing until acceptable drinking water standards are achieved. In addition, stringent closure techniques will be ,,W employed to reduce the risk of on-going leaching from the site. Implementing the State minimum functional standards for land- fills is reducing the potential of future groundwater con- tamination from leachate. Federal and State regulations on the appropriate management of large quantities of hazardous waste are contributing to improved leachate and wastewater sludge qualities. Efforts by the Seattle -King County Health Depart- ment and Metro to identify and work with SQGs are also con- tributing to this improvement. Metro's 1988 Sludge Quality .r Report states, "Metro's sludge quality has improved since 1981, especially in the reduction of metals. ...The continued reduc- tion is largely attributable to a control project to reduce corrosion of water pipes and to Metro's industrial waste source control/pretreatment program." The intent of the Plan is to continue reducing hazardous waste entering the environment and municipal waste streams. This will further reduce the potential for contamination and clean-up responsibility. The Plan sets the goal to reduce the amount of HHW and SQG waste entering the environment and the muni- cipal waste streams to a negligible amount by the year 2004 for HHW and 2009 for SQG waste. The rate at which the plan is implemented has a direct effect on the amount of waste that has the potential to adversely M M0 M am 'Negligible amount COLLECTION FACILITIES: POTENTIAL IMPACTS AND PROPOSED MITIGATION The education and compliance components of the Plan should result in a reduction in the amount of hazardous waste generated as well as increase appropriate disposal practices. This will, therefore, increase the demand for collection facilities and waste handling programs. The plan proposes a combination of permanent and mobile col- lection facilities for household hazardous waste. It also proposes auxiliary and mobile collection facilities for SQGs. Locating and operating collection and handling programs out- lined in the plan could have potential adverse environmental impacts. Earth (soil, site preparation), sensitive areas, drainage, environmental health (public and worker safety), and transpor- tation are impact areas discussed in this section. Design and SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-3 IMPACTS AND MITIGATION MEASURES affect water quality. Table 4-1 indicates the tons of HHW and SQG waste projected to enter the municipal waste streams and .� environment in the fifth, tenth, fifteenth and twentieth years of the Plan, as well as the total tonnage over this 20 -year period. Table 4-1: TONS OF HHW AND SQG WASTE PROJECTED TO ENTER ENVIRONMENT AND MUNICIPAL WASTE STREAMS Waste Type 1990 1994 1999 2004 2009 1990-2009 " HHW 5,941 4,977 1,365 neg.' neg.' 44,038 SQG 12,960 12,750 9,965 3,814 neg.' 160,255 M am 'Negligible amount COLLECTION FACILITIES: POTENTIAL IMPACTS AND PROPOSED MITIGATION The education and compliance components of the Plan should result in a reduction in the amount of hazardous waste generated as well as increase appropriate disposal practices. This will, therefore, increase the demand for collection facilities and waste handling programs. The plan proposes a combination of permanent and mobile col- lection facilities for household hazardous waste. It also proposes auxiliary and mobile collection facilities for SQGs. Locating and operating collection and handling programs out- lined in the plan could have potential adverse environmental impacts. Earth (soil, site preparation), sensitive areas, drainage, environmental health (public and worker safety), and transpor- tation are impact areas discussed in this section. Design and Y aw on SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-4 IMPACTS AND MITIGATION MEASURES No engineering concepts, operations procedures and other measures to mitigate potential adverse impacts are identified. Permanent collection facilities for HHW and auxiliary collec- tion facilities for SQGs will be located and operated at specific sites on an on-going basis. Mobile facilities for HHW and No SQG waste will be located and operated at a site for a limited time, and then move to another prearranged site. Detailed descriptions of these programs are contained in Appendix A. "" The State Dangerous Waste regulations (WAC 173-303) pro- vide useful guidelines for collection site evaluation and facility to design. These include site and facility designs that minimize the degradation of surface and ground water, air quality, ex- cessive noise, and conditions that constitute a negative aesthetic .0 impact for the public using right-of-ways or public lands, or for landowners of adjacent properties. This section proposes mitigation for collection facilities based on these guidelines. am Site specific design, construction and operational features would be evaluated in the environmental review for the project. Collection and Storaze Structure Design 4d M The permanent and mobile HHW collection facilities and auxil- iary SQG collection facilities will likely include a metal shed 2W for temporary storage of the waste, situated on an impervious surface, and fenced for security. Storage units considered by the plan are prefabricated units, designed for storage of w hazardous materials and available commercially. Permanent HHW and auxiliary SQG collection facilities will be set on bermed or curbed concrete pads. HHW and SQG mobile units will use temporary berms or curbs. so The storage units are available in a variety of sizes ranging from 5 feet long and 6 feet wide, to 20 feet long, 8 feet wide ow and 8 feet tall. One or more of these units could be placed on a site to accomodate increasing capacity and waste segregation needs. The units can be moved with a forklift, and are trans- so portable on a flatbed truck. A variety of features to provide spill containment, fire and explosion protection, and worker safety are engineered into the units. Units considered could go have approval from Underwriter's Laboratories, Factory Mutual .r to .. SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-5 IMPACTS AND MITIGATION MEASURES and/or other recognized national testing organizations. This would provide consistency where local jurisdictions have building permit policies regarding prefabricated buildings. Construction -Related Impacts 4W The construction of permanent facilities could introduce short-term adverse impacts through site preparation activities. Specific sites could require grading and/or excavation. Any such activity would be in compliance with local grading permit requirements to mitigate against construction -related erosion and sedimentation. Emissions to the air during construction of a permanent facility would consist of dust, dirt and exhaust from construction equipment. These emissions will be mitigated by operating construction equipment with standard emission control devices, .. and by watering the site to reduce air -borne dust migration. W Grading and paving equipment could increase noise levels in s the vicinity of the site. Construction equipment will be operated with standard muffler systems and during the hours established by local noise ordinances. Drainage The active portion of the site will be paved with an impervious material to prevent potential soil and groundwater contamina- tion in the event of a spill. The impervious surface also optimizes the ability to contain the spilled material (see Contingency Planning and Emergency Procedures below). r" Berms or curbs and portable sumps will provide additional containment to prevent the spread of spilled materials, mitigating the spread of adverse impacts resulting from a spill. r The curbed area of the permanent sites will likely drain to the sanitary sewer system. This requires an industrial waste discharge permit issued by Metro. Drainage will be controlled through the use of lockable drains and/or catch basins, so that contaminants are contained in the event of a spill. r Land Use Lands classified by local jurisdictions as natural, sensitive, conservancy, rural or residential have unique properties that could be adversely affected by collection activities. To the W SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-6 IMPACTS AND MITIGATION MEASURES No extent practicable, the proposed collection sites will avoid these lands, as well as wetlands or lands under jurisdiction of the Shorelines Management Act. The collection facility design and operation will minimize the destruction or impairment of flora and fauna outside the active go portion of the facility. Landscaping of permanent facilities can minimize aesthetic impacts and serve as a buffer between the facility and adjacent properties. •■ Consistency with local zoning codes will minimize real and perceived conflicts between the proposed collection site and r adjacent uses. Local zoning codes identify allowable uses for the properties within a zone and can provide guidance for locating potential collection sites. Local jurisdictions will require land use and building permits for proposed new permanent collection sites; temporary use we permits may be required for mobile collection facilities. As facility planning is initiated, the implementing agency will work with the appropriate local jurisdiction to identify the d permits required and permissible zoning for the proposed activity within the jurisdiction. Locating the facility in a zone permitting the collection activity outright will support the ad compatibility of the use with adjacent uses, and reduce the administrative procedures of changing the land use code or obtaining a conditional use permit. No Generally, local zoning ordinances do not specifically identify zones in which exempted household hazardous waste may be collected. However, all local jurisdictions are required by the so State to amend their zoning ordinances to provide for hazard- ous waste treatment and storage facilities. Appendix B pro- vides examples of the efforts of local jurisdictions in King so County to comply with this requirement. Although the collection facilities proposed in the Plan are not to defined as hazardous waste treatment and storage facilities by the State, local jurisdictions may consider this zoning most representative of the use. However, the types of wastes ni managed at the proposed HHW collection facilities are pro- ducts available at retail outlets (groceries, auto supply and hardware stores) and some SQG wastes are by-products of .r neighborhood commercial services (dry-cleaners, service go as wo SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-7 IMPACTS AND MITIGATION MEASURES stations). Collection of the wastes within the zones generating them would appear a consistent land use. Currently, the predominant means of disposing of HHW (and some SQG waste) is through the municipal solid waste system. Transfer stations and landfills are currently receiving these wastes in the general solid waste stream. These sites have been considered as locations for permanent HHW collection facilities. Providing for the segregation of these wastes at a site currently receiving them would appear consistent with the current land use activity and would eliminate the need to establish a new use at another location. The City of Seattle used this approach to facility siting, ex - .m panding its waste separation capacity at its South Transfer Station by opening a household hazardous waste collection facility. King County transfer stations and landfills, however, .. are currently operating at and beyond their capacity. Establishing a HHW collection facility at these sites would compromise current operations. This plan recommends that, as King County expands its solid waste facilities, permanent HHW collection facilities be considered in the design. Metro wastewater facilities receive that portion of local hazardous waste disposed of through the liquid waste stream. Wastewater treatment sites are under consideration as potential locations for proposed collection sites. As these sites currently handle the subject waste, separation activities would appear to be consistent with the established land use. Environmental Health Risks Although generated in small quantities, HHW and SQG wastes pose a risk to public health when stored in the home or garage and through inappropriate disposal in the solid and liquid waste streams. Residents or employees may be accidentally exposed through a spill, fire or explosion, waste handlers by careless disposal of waste, and fire fighters by unknowingly entering a waste storage area during a fire. The appropriate disposal and management of these wastes will serve to improve public and .. worker safety. The temporary storage of household and SQG wastes at collec- tion facilities could increase the risk of exposure to hazardous chemicals, spills, fire and explosion. Ecology has developed M SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-8 IMPACTS AND MITIGATION MEASURES rr special requirements for facilities managing small quantity ("moderate risk") hazardous wastes (WAC 173-303-560). These requirements are designed to minimize the risks to public users and facility workers. The agency developing a collection facility will incorporate these regulations in its operating procedures. Responsible standard operating procedures and employee training will be required to reduce the threat of spills, fires and explosion, as well as exposure to hazardous chemicals. Occu- pational health laws rank facility design and operations the highest priority for protecting worker safety. Personal protective equipment is considered a secondary measure, where facility design cannot bring the risk of exposure down to acceptable levels. 410 The facility design, responsible handling procedures and house- keeping measures provide the greatest minimization of environ- .r mental health risks. These include proper ventilation, segregation of incompatible wastes, maintaining an orderly storage arrangement, and insuring the correct use of personal ,moi protective equipment. Personnel training and refresher training are crucial to successful implementation of these health protection measures. Although the public user will be on the collection site for a short period of time, there is some potential risk of exposure, No associated primarily with the transport of wastes and the possibility of spills in the vehicle. Exposure could occur as the driver opens the trunk and fumes are released. Public safety will be increased by informing users of safe transporting practices, and by restricting their circulation on or access to the site, depending on the risk involved. The risk of worker exposure will vary dramatically depending on whether some of the hazardous wastes (paints, solvents, motor oil) are bulked at the collection site. If the wastes are packed in drums in their containers, the risk of exposure is limited. Removing the wastes from their containers and combining similar, compatible wastes in drums or bulk containers increases the risk. Bulking certain wastes provides for efficient recycling and reclamation of some chemicals; disposal costs are also greatly we A 9W W SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-9 IMPACTS AND MITIGATION MEASURES +r reduced with bulking. This environmental health risk analysis assumes that some bulking of hazardous wastes will occur at the collection sites, and identifies the following measures and precautions for mitigation. Inhalation and skin contact are the most likely routes of exposure. Volatile chemicals, such as solvents, could be inhaled directly; other chemicals could be inhaled as particles. Proper handling procedures, facility design, and the use of personal protective equipment will minimize these risks. Facility employees will wear eye protection and chemical -resistant gloves and clothing at all times when working at the facility, minimizing eye and skin contact. Bulking will only be performed where there is adequate ventilation. Respirators will be readily available and used during bulking operations and prolonged work periods inside the storage unit. Simple testing of total organic solvents using passive dosimeters (measuring devices worn by workers that indicate exposure to solvents) are appropriate when workers are involved in bulking solvents and solvent -containing wastes. Contingency Planning for Emergencies A contingency plan and emergency procedures for hazardous waste facilities, including those managing small quantity hazardous waste, is required by Ecology (WAC 173-303-350) and local fire departments. The protocols will identify the means of minimizing environmental health risks in an emer- gency situation such as fire, explosion, or release of waste to air, soil, surface water or groundwater. The contingency plan must contain the following elements: A description of actions the facility personnel must take in such events. A hierarchy of decision-making and responsibility is also recommended. r • Actions in the event of receiving damaged or otherwise threatening waste that is not acceptable to the operation; e.g. explosives, asbestos, infectious and nuclear waste. W 4W SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-10 IMPACTS AND MITIGATION MEASURES Emergency Response • Arrangements made with local police, fire, hospitals, contractors, and State and local emergency response teams, to coordinate services. • Current list of names, addresses and phone numbers of those qualified to act as coordinator in the event of an "" emergency. • A list of all emergency equipment, including location r on-site; e.g. fire extinguishing systems, spill control equipment, communications and alarm systems, decontamination equipment. �r • Evacuation plan. .r A trained emergency coordinator will be at the site or on call at all times. The coordinator is responsible for a thorough familiarity with all aspects of the facility's contingency plan, .r all operations and activities at the facility, the location and properties of all wastes handled, the location of all records within the facility, and the facility layout. The coordinator , will have the authority to commit resources needed to carry out the contingency plan. Action will be immediately taken when any hazardous waste or go substance is accidentally or intentionally spilled or discharged into the environment where public health or the environment so are threatened. The following procedures based on WAC 173- 303-360 provide direction to the emergency coordinator in the event of an emergency. The actions are means of reducing the threat of worker or public exposure to hazardous chemicals and AW the degradation of the environment. The emergency coordinator will be responsible for immediately notifying all facility personnel, Ecology and the local fire department of an emergency. All reasonable measures neces- sary to insure containment and mitigation of the spill would be "r implemented. Employees responsible for containing or controlling the event No would put on personal protective equipment before attempting W e .. `W SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL 4-11 IMPACTS AND MITIGATION MEASURES •r control measures. Liquid spills would be cleaned up with ab- sorbent material; solid spills would be diluted with absorbent if appropriate and swept up. All contaminated material would be placed in containers and disposed of as hazardous waste. All contaminated equipment and surfaces would be thoroughly decontaminated before operation is resumed. In the event of a fire, facility attendants would employ the .. actions provided for in the contingency plan. Appropriate actions will be determined on a site by site basis depending on the facility engineering and staff training. After all emergency events, the incident and response would be evaluated to determine what procedures could prevent a recur- rence, and evaluate the emergency response. Records of all events will be kept and used to notify appropriate agencies. Possible hazards to human health and the environment (direct, indirect, immediate and long-term effects) resulting from the event would be assessed and the findings reported to the appropriate local, state and other government officials if human health or the environment outside the facility is threatened. Transportation Existing state and federal laws regulate many aspects of hazardous material and waste transportation. Many of the regulations exempt HHW and SQG waste, but hazardous waste treatment and disposal facilities will not accept materials that qW do not comply with the regulations regardless of exemptions. W M r an The transportation of hazardous wastes collected at permanent and mobile collection facilities will meet all applicable federal and state regulations for transport including safety, equipment standards, packaging, labeling, training and manifests. All collected waste will be packaged in a manner acceptable to a permitted treatment and storage facility and the ultimate disposal site. Transporting service will be provided by a hazardous waste transport company through a contractual arrangement with the implementing agency. The transporter will be in compliance with the State regulations for trans- porters of dangerous waste, WAC 173-303-240 through 270. SECTION 4 AFFECTED ENVIRONMENT, POTENTIAL IMPACTS AND MITIGATION MEASURES Routing of Hazardous Wastes In the event of a spill during transport, the transporter will comply with notification, mitigation and containment and clean-up procedures outlined above for spills or discharges into the environment, as required by WAC 173-303-145. Traffic and Circulation at Collection Sites The proposed collection programs will vary in the volume of traffic generated per operating period. The current HHW collection service at Chemical Processors, Inc. receives an average of 30 vehicles per operating period (6 hours/day). The City of Seattle's South Transfer Station HHW collection facility has the capacity to handle 60 vehicles per day. Site access and circulation are critical for safe operation. Potential site evaluation would assess the ingress and egress for the site, and the capacity of the access road to safely handle vehicle overflow. The site design will ensure adequate space and sight distances for safe vehicle and worker circulation. ■.r wr .r .. aw 771 No r M 17 F9 Hazardous waste transportation routing reduces the potential exposure of individuals and property to accidental releases of wastes. Federal regulation 49 CFR 397.9 states that unless there is no practicable alternative, a vehicle containing hazard- ous materials must be operated over routes which do not go through or near heavily populated areas, places where crowds — = assemble, tunnels, narrow streets, or alleys. Some local juris- dictions have designated hazardous materials routes, or restrict gPp�e��a or prohibit transporting hazardous materials over specific �azardoos routes. An example of a local restricted route is the Alaska W Way Viaduct, located in downtown Seattle, Washington. Alternative transport routes will be evaluated as collection sites are identified. Preferred transportation routes from the col- lection sites will be designated and used by the transport ser- vice, and to the extent practicable, by the public. Locally established hazardous materials transport routes will be utilized where available, and those routes prohibiting such transport will be avoided. These routes will minimize adverse impacts associated with delivery of the waste to the collection site, and removal of the waste by the hazardous waste transport service. In the event of a spill during transport, the transporter will comply with notification, mitigation and containment and clean-up procedures outlined above for spills or discharges into the environment, as required by WAC 173-303-145. Traffic and Circulation at Collection Sites The proposed collection programs will vary in the volume of traffic generated per operating period. The current HHW collection service at Chemical Processors, Inc. receives an average of 30 vehicles per operating period (6 hours/day). The City of Seattle's South Transfer Station HHW collection facility has the capacity to handle 60 vehicles per day. Site access and circulation are critical for safe operation. Potential site evaluation would assess the ingress and egress for the site, and the capacity of the access road to safely handle vehicle overflow. The site design will ensure adequate space and sight distances for safe vehicle and worker circulation. ■.r wr .r .. aw 771 No r M 17 F9 2K� » on SECTION 5 RESPONSIVENESS SUMMARY 5-1 COMMENTS AND RESPONSES ON THE DRAFT PLAN/ENVIRONMENTAL IMPACT STATEMENT FOR THE LOCAL HAZARDOUS WASTE MANAGEMENT PLAN This chapter contains copies of comment letters received during the public and agency review of the Draft Plan/EIS. The interagency Technical Planning Committee's responses follow copies of each of the letters. The underlined numbers in the responses correspond to numbers found in the margins of the comment letters, denoting discrete comments. The 30 -day public comment period for the DEIS began on February 24, 1989, and extended through March 27, 1989. Comment letters were received from the following agencies, organizations, firms and individuals. List of Commentors on the LHWMP DEIS Public A envies U.S. Environmental Protection Agency, Region 10 Puget Sound Council of Governments Regional Environmental Affairs Committee King County Parks Planning and Resources Development City of Auburn Planning and Community Development City of Bellevue Storm and Surface Water Utility City of Seattle Fire Department City of Seattle Department of Human Resources Industries Chemical Processors, Inc. Oregon Waste Systems, Inc. Safco Environmental and Thermal Energy Corporation Citizen Groups The Mountaineers Seattle Audubon Society Washington Toxics Coalition Alliance for Solid Waste Alternatives rr M SECTION 5 RESPONSIVENESS SUMMARY 5-2 Vashon Island Groundwater Management Advisory Committee so Metro Citizens Water Quality Advisory Committee County Citizens for Responsible Waste Management Community Associations Institute '~ Individual Citizens fm Michael Piel Karen Stevens M.E. Blau Peter H. Vogel Jack Brautigan Susan F. Colton Gregory R. Allan .r W sw M so r A 4W US ENVIRONMENTAL PROTECTION AGENCY REGION 10 N'`EO 54rf , I2UG SIX1 H AVENUE s of SEATTLE. WASHWGTON 98101 2 �`�'/!,r•R 4 1989 +t c` A4 PROIE viii (�I WD -136 t Gregory M. Bush, Manager Metro Environmental Planning Division ` MS -92 821 Second Avenue Seattle, Washington 98104 Re: Draft EIS - Local Hazardous Waste Management Plan for Seattle - King County Dear Mr. Bush: EPA has reviewed the subject document and suggests that the requirements for small quantity generators (SQG) be clarified. On page 2, paragraph 1, the 1 DEIS states that SQGs "are not currently regulated." EPA regulations (40 CFR 261.5) specify conditions under which SQGs could qualify as being "conditionally" exempt, and various ways in which an SQG may be subject to full regulatory requirements. Enclosed is a copy of the EPA regulations and a handbook on SQG rules. For further information on EPA requirements applicable to SQGs, please contact Nina Kocourek of our Waste Management Branch at 442-6502. Thank you for the opportunity to comment on the DEIS. Sincerely, /Gerald .�Oppaat'zChief Environmental Review Section Enclosure Your Seattle � 1 MAR 1939 • Fire Department Claude Hems, Creel U Charts fioyar. Maya March 20, 1989 i Mr. Richard Yukubousky, nirector Office For Lono Ranoe Plannino City of Seattle Pear Mr. Yukubousky: I have reviewed your Local Hazardous Waste Management Draft Plan/FIS. I find this document to be well thouaht out. There is one area as it relates to the Seattle Fire Code (FFC) that some clarification is renuirel. In the SFC, under "Reporting of Fires" section II.?O1(a) states: "Tn the event a fire or accidental release of a hazardous material occurs or fire alarm operates on any Property, the owner or occupant shall immediately report such fire or alarm to the vire neoartment." I would like to see this reouirement incorporated into vour Draft Plan/FTS to provide your people and/or the public with immediate assistance should an unforeseen emergency arise. should you have any questions contact Chief P. L. Hansen, Fire Marshal, at 3R6-1450. very trulv yours, Clau a Harris, ief SPattle Fire Denartment CH:rmrl:mm An equal employment opportunity - affirmative action employer. City of Seattle—Fee Department, 301 Second Avenue South, Seattle. Washington 9610/.(206) 3861400 "Pinted on Rmycled Paper" 5-4 RESPONSE TO U.S. ENVIRONMENTAL PROTECTION AGENCY 1. This plan addresses small quantity generators as defined by the state Department of Ecology Dangerous Waste Regulations. The state definition of SQGs are those businesses generating less than 220 pounds of hazardous waste per month or batch. Some extremely hazardous wastes are regulated down to 2.2 pounds or less. RESPONSE TO CITY OF SEATTLE FIRE DEPARTMENT 1. Comment noted. Section 4, page 9 references contacting local fire departments as a part of Contingency Planning for Emergencies. The SFC is specifically referenced as the plan is intended for adoption by King County and other incorporated jurisdictions, as well as the City of Seattle. Regional Environmental Affairs Committee Puget Sound Council of Governments w ­c_.. air»— s.a AWU—AM1-1W March 10, 1989 Gregory M. Bush, SEPA Responsible Official Local Hazardous Waste Management Plan METRO Environmental Planning Division MS -92 821 Second Avenue Seattle, WA 98104 Dear Mr. Bush: The Regional Environmental Affairs Committee appreciates this opportunity to review the drafL Local Hazardous waste Management Plan (February 1989). We strongly support the collaborative approach used, and in this spirit we offer the following suggestions: 1. Context Gregory M. Bush March 10, 1989 Page Two change might justify a broadened set-aside fund for several kinds of local programs, to be supported in part by Initiative -97. Local hazardous waste plans may provide the opportunity now for the state and local governments to explore this efficient approach. 3. Relationship to Federal Programs Waste reduction is the mission of the new Pollution Prevention Office formed by the Environmental Protection 3 Agency. This is announced and described in the Federal Register, January 26, 1989. This may benefit from, and provide support to, your proposed Resource Library (element A-31). 4. Relationship to Other Programs References are made to solid waste, water quality, and The hazardous waste strategy in this state is multi- groundwater programs. In addition, certain elements in faceted and sometimes confusing. In your introductory the Plan might be presented as implementation steps remarks you might note that hazardous wastes from within the various Groundwater Managemant Plans, and 1 large sources total 96,448 tons/year (1986 State therefore, eligible for funding under the Centennial Hazardous Waste Annual Report), and that your plan Clean Water Fund. This possibility should be explored enables households and small businesses to directly /1 with the groundwater lead agencies, and Ecology. address an additional amount (from individually �} insignficant sources) equal to 1/5th of the amount to be (One important step (based on p. 2-23) could be a search addressed in the State Plan. for alternatives to trichloroethylene as a septic tank cleaner.) 2. Relationship to State Plan 5. Door-to-door Pickup a. If the barrier to an effective waste exchange (element A-29) is threshold volume, then the Plan This action is found to be too expensive. However, ght explc.-e s joint waste-exchango within our since 59 percent of household hazardous wastes are larger region, or with the State. If this has paints (Fig. 2-5), might thARA be collected door -to - merit, it should be accommodated in any waste door, perhaps at the time of home sales. exchange proposed by the state in its Plan. 2 Special facilities located at the transfer stations b. The state hazardous waste cleanup task force, in might be another approach. its meeting on December 6, 1988, was informed by the state that a waste management block grant 6. Siting approach might be possible. If so, this policy Pursuing the difficult issue of siting, how many sites might be needed, and how large? Could these be operated in conjunction with the existing automobile inspection ... for the first time in the history of the indusrrial age, business climate and quality of life are becoming increasingly and Maintenance sites? synonymous. Jodi), a gmilu) envrunment is an economic asset. It is also an ecological necessity." (Washington State Economic Development Board) Gregory M. Bush March 10, 1989 Page Three Concerning size, if a 55 gallon barrel weighs 400 pounds (probably conservative), then 100 percent reclamation of the total local hazardous waste problem would produce 317 barrels per day (for the 13,000 tons/year of commercial/industrial waste, and 6,000 tons of household waste.) How many cars per day would be involved for this and the less aggressive alternatives? What does this look like on the ground? 7. Ranking of Elements Priorities should be based in part on a comparison of marginal costs (the costs shown in the Appendix for each element) compared to the marginal reduction in the total problem documented in the Plan. For example, how would item 5, above, compare to other actions costing less, but also dealing with less of the total hazardous waste problem? We congratulate you and the full team of authors and principle contributors to the Dreft Plan. In the above comments we hope to focus and share with you the benefit of our work as an environmental roundtable. Please call on us if we can be of further service. Very Truly Yours, Councilmember Lois North Chair, REAC 5-7 IRESPONSE TO LETTER FROM PUGET SOUND COUNCIL OF GOVERNMENTS 1. Comment noted. 2. Relationship to State Plan. a. The Seattle -King County Health Department is currently developing a passive waste exchange program. The program is being developed on an international basis, coordinating with other established programs in western �i► United States and Canada (California, Idaho, Montana and British Columbia). The state Department of Ecology has not developed a program at this time. In addition, Spokane proposed a program but has not initiated one at this time. The contact person with the Seattle -King County Department of Public Health is Jerry Henderson. He can be reached at 296-4633. b. The Final Plan/EIS proposes the use of Local �,. Toxic Control Account funds as a primary funding mechanism for local hazardous waste programs. A block grant approach would provide efficient administration for both the State and local jurisdictions. The result would be less money lost in administrative overhead. The planning staff supports the approach with the allocation of the grant funds based on population served or on amount of waste generated W within the area. 3. Comment noted. 4. Comment noted. 5. Door-to-door pick up is expensive in that special staff and pick up vehicles are needed to handle hazardous wastes. A great portion of the program expense comes from the labor - hours involved in a pick up program. This includes setting up appointments, assigning daily schedules, driving from one appointment to the next, and collecting and loading the waste. In addition to the expense, this collection method requires someone from the household available for the appointment. The City of Seattle is currently evaluating the potential for recycling discarded latex paint. As opposed to solvent - based paints, latex paints may not be hazardous. However, not all latex paints may be suitable for recycling; about half could remain for disposal. Analyses on the non - recyclable latex will determine whether it requires disposal as a hazardous waste, or whether it can be solidified and disposed in a municipal landfill. 0 RESPONSE TO LETTER FROM PUGET SOUND COUNCIL OF GOVERNMENTS (continued) Irrespective of how the latex paints are handled, either as a hazardous or non -hazardous material, alternative collection mechanisms to the door-to-door pick up are likely to be more efficient. Collection at transfer stations or at HHW collection facilities is more likely. The evaluation element of the Final Plan ensures the effectiveness of the implemented programs will be reviewed, and the programs modified, as needed, to achieve the objective of diverting the maximum amount of HHW. A HHW collection facility currently operating at the Seattle South Transfer Station accepts paints for households. 6. The Recommended Program proposes 6 permanent HHW collection facilities and 2 mobile units to collect HHPJ. The collection sheds are generally 81X8'X2011 in dimension, and operate in an area large enough to accommodate a 15' buffer around the storage buildings. The current siting criteria for the North Seattle HHW collection facility includes considering publicly -owned lands, particularly by the City of Seattle or Metro. Should a state Department of Licensing inspection and maintenance site be optimally located, the implementing agency would work with the state to determine the feasibility of operating a HHW collection facility on the site. The recent experience at the Seattle HHW collection facility shows an average of 25 to 40 vehicles per week averaging 100 pounds of waste per vehicle. 7. Many of the programs complement one another. The effectiveness of each program is difficult to quantify at this time. The evaluation component of the plan will address cost-effectiveness of individual programs, as well as the overall effort of the plan and components. 1.{uq ru..11l. 1'.u�l.., PLu.uinp .wd ue,.m..an U.q.,u�nurnl I20h):lu 7.0 13 March 23, 1989 f f f f Ir f f f I 1 f r 9' it Gregory M. flush March 23, 1989 Page 2 ternatives will be implemented is important to any review of the plan and any selection of an appropriate alternative for managing hazardous wastes. Gregory M. Bush, Manager Metro Environmental Planning Division 821 Second Avenue MS -92 Seattle, WA. 98104 RE: Comment Concerning Proposed Local Hazardous Waste Management Plan for Seattle -King County Dear Mr. Bush: -Thank you for inviting King County's Parks, Planning and Resources Department to comment on the above -referenced draft Lo- cal Hazardous Waste Management Plan and corresponding environmen- tal impact statement ("DEIS"). Since the department was only provided with a summary of the plan and the DEIS, the following comments are based upon the summary which presumably includes the significant features of the plan and DEIS. The plan summary outlines several alternatives for collecting, handling and disposing of household and small quantity hazardous wastes. Essentially, the alternatives differ, based on their costs and project completion dates. Reviewers of the plan, such 2 as our department, were asked to select a preferred alternative. We, however, are unable to comply with that request. In spite of the fact that the summary is intended to digest the proposed plan and the DEIS, it provides no information concerning the environ- mental impacts resulting from each alternative considered. Without this information, it is impossible to distinguish among the alternatives because it is impossible to correlate the added cost of each alternative to a specific degree of enhanced benefit to the environment and the general public interest. In addition, the summary neither clearly identifies the agencies which will have roles in executing the proposed plan nor the roles of the participating agencies. This information is impor- tant to any in-depth review by this department. If we are to par- ticipate in the implementation of the plan, e.g. by zoning for hazardous waste collection and transfer facilities or by perform- ing some other duty, a prior knowledge of our responsibilities would assist us in assessing the feasibility of the various al- ternatives. Certainly, a more precise description of how the al - It is a positive step toward effective management of household and small quantity hazardous wastes to incorporate and emphasize public education. There is no doubt that a change in public thinking is necessary to create a change in public behavior --a change in the way we dispose of our (household and small quan- tity) hazardous wastes. However, it appears that education, alone, is the avenue by which the plan intends to reduce the production of hazardous wastes. Where possible, more persuasive 4 methods of reducing wastes should be used, e.g. incentives and penalties. According to the proposed plan, household and small quantity hazardous wastes are intended to be taken to regulated treatment, storage and disposal ("TSD") facilities for ultimate disposition. It is unknown whether existing TSD facilities are adequate to handle 100% of all such wastes, as contemplated by the proposed plan. Furthermore, future siting of additional facilities will likely be arduous and time-consuming. Therefore, greater emphasis must be placed upon waste reduction than the more uncertain and limited methods of hazardous waste treatment, storage and disposal. Finally, the plan has as its goal 100% diversion of hazardous wastes from local solid waste facilities, wastewater and the en- vironment. However, the plan does not provide for adequate monitoring by which the plan's success rate may be determined. 5 We recommend that additional monitoring features be incorporated into the proposed plan including comprehensive testing of solid waste facilities, wastewater and other parts of the environment for the presence of hazardous wastes once the plan is imple- mented. Thank you for your consideration of our comments. Sincerely, Bryan Glynn Director BG:SES:ses cc: James C. Tracy, Manager, Building and Land Development Division ATTN: Ralph Colby, Manager, Technical Services Jerry Balcom, Supervisor, Code Development Susan Stewart, Planner 5-10 RESPONSE TO LETTER FROM KING COUNTY PARKS, PLANNING AND RESOURCES DEPARTMENT 1. It is regretful that the department received the summary rather than the full Draft Plan/EIS. 2. The hazardous waste management alternatives described in the draft plan were not site specific. When specific programs are proposed for implementation following the adoption of the plan, site specific environmental reviews will be required. The net result of implementing the Local Hazardous Waste Management Plan will be improvement of the environment and the municipal waste systems. 3. The Draft Plan/EIS evaluates several hazardous waste management alternatives for public review. The Final Plan/EIS identifies agency roles and responsibilities and describes plan implementation. The implementation approach was developed based on comments received on the Draft, and was further reviewed by affected agencies before the Plan was developed. 4. Waste reduction is the highest priority for the plan, in keeping with the Department of Ecology's ranking. It is a central component of the Plan. Education, especially for households, is a primary means of changing behavior. Therefore, education is an essential part of the waste reduction program. However, other techniques are included in the Recommended Plan. These include various incentives to encourage Sqgs to properly handle their waste, including technical assistance and a limited subsidized disposal program. The Plan also proposes a compliance program for small quantity generators comprised of audits, surveys and follow-up inspections. Load -checking of waste from self -haulers at transfer stations is an additional compliance proposal. Research for the plan included discussions with TSDs in the region to determine the capacity of existing facilities. In addition, the TSDs reviewed the Draft Plan/EIS. Adequate capacity exists for handling the waste collected through the proposed programs. Increased volumes may, in fact, benefit some reclamation and treatment processes, and other economies of scale. 5. The evaluation component of the Final Plan ensures the effectiveness of the implemented programs will be reviewed, and the programs modified, as needed, to achieve maximum 1 1 L-A RESPONSE TO KING COUNTY PARKS PLANNING AND RESOURCES DEVELOPMENT (continued) effectiveness and efficiency. includes funding for program will include monitoring waste the amount of Hazardous waste the plan will be evaluated an 5-11 The budget for the plan evaluation. The evaluation streams to measure changes in being disposed. In addition, d updated on a five-year cycle. r .. I'V i.1tt111 t1/r. \\ NtANN fr. 6 AtaU Ct)MMON11Y(A +' ILLI YMf ti l Ut I" 1.1 fn1 �1•I rri t,, Iill. I 1, r ' J :t, W!_ SI MAIN. AU©UHN, WA 9611 l Gregory M. Bush 120619313090 Local I lazardous Waste Management Plan For Seattle -King County Draft EIS — -- —----_-- ---- Stir iM -- March 31, 1989 Page Two March 31, 1989 Ref. No. 89-200 The management of hazardous materials in both small and large quantities must receive equal attention during collection, storage and transportation. In particular, there is no way to ensure that unstaffed Gregory M. Bush, Managcrcollection sites designed to receive small amounts of hazardous waste will be operated in a safe manner. Mcln> Environmental Planning Division 2 Therefore, we would recommend that permanent collection sites be attended on a 24 hour basis. A 821 Second Avenue MS -92 collection fee may be necessary in order to provide such services, but would significantly improve safely Seattle, WA 98104 and management of the collection facilities. Re: Local Hazardous Waste Management Plan For Sealtle-King County Draft EIS^ Mobile collection or roundup situ are difficult to manage, in that incompatible materials must be kept ssegregated. This requires numerous round trips to storage sites, or restricting the items which are The following comments are related to the Local Hazardous Waste Management Plan and Draft collected. This process may result in a costly and unproductive collection service. Environmental Impact Statement (DEIS). In responding to the DEIS, we have broken our comments into two areas including policy and procedural issues, and technical issues. Infrequent or irregular collection days have not yielded a quantity of household wastes that would justify such a program. Alternatively, the City would favor a program that allows a homeowner or business owner to drop off wastes at a convenient site. This alternative would not preclude local collection of Policy and PrOCCLIural Issues certain materials on specified days, and delivering them to a designated permanent collection facility. It is our understanding that the process for completion and adoption of the plan is two fold. First, the DEIS protides technical information related to hazardous waste management issues and the four Conclusion proposed alternative management strategies. Secondly, comments received through the DEIS comment period will be used to shape the content and selection of a specific management strategy and The City fully recognizes the value of addressing hazardous waste management on a regional basis. implementation policies. This strategy will become the Loral Hazardous Waste Management Plan However, adoption and implementation of a regional program requires significant policy consideration transmitted for adoption by each participating jurisdiction. and commitment of financial resources for implementation. We strongly encourage you to provide sufficient opportunity and process to ensure that these decisions can be resolved with the participating While the process for review and comment on the DEIS provides sufficient opportunity to discuss the jurisdictions prior to moving forward with the adoption process. Thank you for the opportunity to review technical merits of the draft Plan and it's recommendations, there has not been an opportunity in this the DEIS. If you have any questions, please give me a call. process to discuss financing obligations, implementation responsibilities or policy implications. Management of hazardous waste is obviously a regional issue. However the means to achieve this 1 Very truly yours, regional management are diverse, and require careful consideration. In addition, the Plan will be ineflccti+'c unless it can be agreed upon by all participating jurisdictions. Within the context of the DEIS Department of Planning and Plan process, there is no apparent forum or process for reaching a consensus on the Plan's ultimate & Community Development recommendations. It would Lo the City's cspcclelion that an appropriate forum for discussion of regional policy issues would be conducted prior to requesting that the Plan be adopted by each kcal jurisdiction. This process Mary McCumber would ensure, or indicate whether the Plan can be agreed to based on a regional consensus, and would Director allow for appropriate decisions to be made regarding selection of a lead regional agency, regional progralm financing opportunities and responsibilities, and local implementation and financing MM:aw rc>ponsihililics. Failure to reach this consensus prior to requesting action on the Plan individually, may significantly jeopardiic the Plan's adoption and implementation by local jurisdictions due to these cc: Bob Rocgner, Mayor siguif icaut policy questions. Pat Dugan, Finance Director Bob Johnson, Fire Chief Frank Currie, Public Works Director I cchnic_d lstiuks Suburban Cities Planning Directors Suburban Cities Public Works Directors ONcrall, the CitY concurs with llle technical analysis provided in the DEIS. There are sufficient Suburban Cities Fire Chiefs allcrnaivcs evaluated in [tic DEIS from which to develop a quality hazardous waste management plan. I tic following uullines it Icw specific comments related to the technical analysis. —4 _�,.... 4 t,,—... t .., &,-- L .• -'a & -. --- 5-13 RESPONSE TO LETTER FROM CITY OF AUBURN 1. Recognizing the need for regional consensus on the plan, the lead agencies responsible for developing the Local Hazardous Waste Management Plan for Seattle -King County have worked throughout the process to involve the suburban cities. A representative of the Suburban Cities Association was a designated member on the Technical Planning Committee (TPC) responsible for drafting the plan. Suburban cities elected officials and technical, planning and administrative staff were encouraged to review the Issue Paper and participate in scoping for the DEIS during August, 1988. The lead agencies have continued to identify and provide further opportunities for participation by suburban cities. Each suburban city received notification and, at a minimum, a summary of the Draft Plan/EIS released February 27, 1989. The Draft Plan/EIS was a policy issue on the March 1, 1989 and April 19, 1989 meeting agendas of the Solid Waste Interlocal Forum; three of its members are selected by the Suburban Cities Association. Members of the TPC made a presentation on the Draft Plan/EIS at the April 12, 1989 meeting of the Suburban Cities Association. To facilitate discussion on the developing Final Plan with the suburban cities, a workshop was conducted on June 7, 1989. Both elected and administrative officials from the cities were invited to participate. Eleven cities sent representatives. Informational material provided at the workshop was sent to cities not represented, with a mail - back form to submit with any comments. The suburban cities will continue to have the Solid Waste Interlocal Forum, the Suburban Cities Association and representation on Metro as forums for discussing the Final Plan. 2. The HHW and SQG collection sites will be operated by trained personnel. In the event HHW is stored on the site during non-operating hours, the collection shed will be secured by locked doors and fencing. Attempts will be made to site the shed at locations with 24-hour a day personnel activity, such as a solid waste transfer station or wastewater treatment facility. However, it would be prohibitively expensive to exclusively staff a HHW collection facility on a 24-hour basis. 3. Well-designed sorting areas and trained staff have enabled Round -up events to operate safely. Permanent and mobile collection facilities will use trained staff and storage sheds that are engineered with safety features, including compartments for segregating wastes. 5-14 1 RESPONSE TO LETTER FROM CITY OF AUBURN (cont.) I 4. The Plan includes collection of HHW at permanent locations and by mobile facilities as a means of increasing convenience and accessibility. The collection program will include the transporting and treatment/disposal of the collected waste. I 1 �I 1 1 r r M r r M M" r MONI= M mm am M W ,A1:,1. L m Cit of 1 B(� Y �GsI'. ti!!��„. t'� 1, 11001”, 41'.l•,IlnhilC�'"1.41ki11U?1411)11 2Sv. StG subsidy should be phased ut•t early in rte 20 year edlev u�:�'v.'� =,� 6ShINt� planning cycle. Government can help establish proper waste management programs but may not be able to provide bt:sines:: subsidies throughout time. March 27, 19H9 • City of Bellevue Sewer Utility may not support an increased sewer rate to finance the plan. Their efforts are geared at 7 keeping HM's out of the sewage waste stream and an ongoing tax on Gregory M. Bush, Manager sewer utility customers represents an unfair burden. SLPA Responsible Official Metro Lnvironmental Planning Division • The City of Bellevue may agree to pay a portion of the cost 821 2nd Avenue KS -92 based on population if an evaluation identifies that it is ar: Seattle WA 9H104 equitable assessments. Dear Mr. Bush: • A tax on HM products more equitably charges those that use them. A user fee on collection services does not encourage City of Bellevue staff have reviewed the February, 1989 Draft proper disposal. Local Hazardous Waste Management Plan for Seattle -King County. The document dvd proposed alternatives represent an, extremely + Several of the SQG programs identified in the Flan seem to comprehensive program and an overwhelming effort. We commend the fall under state role (ie, DOE's Waste Reduction and Recycling 1 authors and principal contributors. However, due to the complex- ity of t.11e proposed program, the variety of potential final plar. Division)The followingwhighicost program elements should be . to options, and the potential financial obligations the City of coordinated by the state ith nformation/assistance provided local programs: SQG Telephone Information Line; Promotion of SQG Bellevue is concerned that this draft plan represents the only Waste Reduction, Recycling and Treatment Programs; SQG Waste opportunity to comment and influence what is detailed in the Characterization and Treatment Feasibility; Hazardous Materials final plan. Disclosure Ordinance. In addition to our request to have additional opportunity to It is unclear whether consideration was given to combining HHW comment on the development of the final plan we have the follow- and SQG Waste Collection at the same sites. It could streamline Inc comments on the draft plan. 0 , the numb�ar of sites and �taff needed. May need to be run by private TSD's to accomplish. Bellevue would be interested in 2 Small Quantity Generator (SQG) plan components should be budgeted separate from Household Hazardous Waste (HMW) compo- reviewing a cost comparison. nents. * Can Response Network element and Surveys and Audits element be incorporated into existing inspection /response programs (ie, 3 The final plan should attempt to divert 1001 of the HHW and Fire department inspections, Haz Mat and Water Quality response SQG waste within 20 years. programs) by adding training and new personnel. 24 new inspec- 1 tors in the Response Network and St•rvegs and audits elements " Consideration/evaluation should be done on using all mobile seems like a lot. An evaluation may identify duplication in site units that visit different sites on a regular weekly schedule ntsi visits already being done. A big cost is arranging and travel to (ice, 1 mobile unit that covers 2 regular q (permanent) sites each site. -Friday, Saturday, Sunday and Monday of week 1 at site A; Friday, 4 Saturday, Sunday and Monday of week 2 at. site B). Siting and Is there an artificial escalation in cost estimates due to all zoning for mobile units should be simpler. Yearly Roundups are//� the program elements being developed and budgeted separately? not in acceptable option since they de not provide regular, 12 Are there areas where efforts can be combined? onyoiny service. * Finance and Implementation should be determined after more of • It is unclear wt:etl•er the development of tre program and the final plan details are identified. A system to ensure plan Pro cost:; take education/waste n -eduction efforts over time ^ 3 implementation should be established. Participating jurisdic- 5 into cc ns id( -cation. it seems that even with population turn ....wd+. t,.. ahuuld not Continue to increase given the v tions should he involved in the decision. compr,•henr• i ve and Cue.t I c0uca ti on efforts outlined in the tlaxImum Div( -r:. i,.ln and Phased Diversion aIternar ives. i : it 301 1 1 GO I r wt;I lug : ; L. t. I Again the authr rs and 1rincipal contributors to this draft plan should be commended for their extensive effort and thoroughness. Please call myself at 451-447b or Sarah Ilubbard-Gray at 453-4895 to discuss our comments and concerns. Thank you for the opportu- nity to review and subm4t comments. Sincerely, Damon Diessner J Director DD:sk cc: Chuck Mize, City Manager's Office Toni Cramer, Design and Development Department Geoff Ethelston, Water and Sewer Utility Chris Dewey, Fire Prevention Sorja Alexander, Risk Manaqement -� Rob Odle, Planning Rick Kirkby, Legal bush.ltr MON r MAN M" saw a r 5-17 RESPONSE TO LETTER FROM CITY OF BELLEVUE 1. See response to City of Auburn, item 1. 2. Small Quantity Generator plan components are financed and budgeted separately from Household Hazardous Waste components. The fee structure establishing separate fees for household and commercial solid waste accounts is described in the finance part of Section 3, Plan Description. 3. The goal of the plan is to reduce the input of hazardous substances to municipal waste streams and the environment by a significant, measurable amount. The Final Plan/EIS recommends an intensive effort to divert the maximum amount of HHW and SQG wastes feasible from disposal in the municipal waste streams over the next twenty years. One hundred percent diversion is the ultimate goal of the program implementation. However, it is realistic to acknowledge that some amounts of hazardous waste will elude the diversion programs and enter the environment. 4. The Technical Planning Committee, responsible for developing the plan, concurs that yearly Round -ups are not an effective means of providing regular, on-going HHW collection service. The plan proposes a mix of permanent and mobile collection facilities to provide an optimum level of service in the region. 1 5. Waste quantity projections were made based on the following procedures. 1) HHW and SQG wastes are currently 1% of the solid waste stream. 2) HHW and SQG wastes are currently disposed of in the solid waste and liquid waste streams at a ratio of 85% to 15% respectively. 3) Tons of HHW and SQG wastes were projected by 1% of the King County Solid Waste Department projected tons of solid waste over the next 20 years and increased those projections by 15% to account for the portion in the liquid waste stream. 4) Waste reduction goals for each category of hazardous waste were derived through best professional judgment. 5) The reduction goals were used to project the tons of waste reduced each year. Even an aggressive and optimistic reduction program will result in continued increase in amounts of SQG waste and HHW. This is a result of projected growth in the region, and knowledge and technology available at this time. It is possible that innovations in waste reduction and recycling over the next 10 to 20 years will allow even higher Ireduction goals to be reached. 6. The subsidy element of the SQG program is recommended for the first five years of the plan. This program element 1 5-18 1 RESPONSE TO LETTER FROM CITY OF BELLEVUE (cont.) I does not provide a long-term business subsidy. Rather it is an inducement to affecting wide scale changes as rapidly as possible. An individual SQG would not receive funds for the five years. The funds will be made available to initiate proper waste management procedures. The subsidy offers the SQG a way to offset the costs associated with profiling, testing and equipment that are incurred as they begin to manage their wastes properly. The SQG must agree to specific changes regarding their waste management practices and must qualify as an SQG before money is made available. 7. The financing mechanism proposed includes fees levied on solid waste haulers and on sewage treatment plants, instituted by the King County Health Department. This fee would be collected on an annual basis. Details of the financing program are described in the finance part of Section 3. S. The Final Plan/EIS assumes funding from the current Local Toxic Control Account revenues for the implementation of local moderate risk waste plans. Further, it recommends the State grant authority to local governments to institute a local addition to the hazardous substance tax (a tax on the first "possessor" of hazardous materials in the state). Neither of these sources will be sufficient to fund the entire plan, and it could take a minimum of one to two years before a local addition to the hazardous substance tax could be approved by the legislature. Therefore, local sources of funding are necessary to supplement state funding, especially in the initial years of the plan. User fees were considered for HHW collection programs, but are not recommended due to the potential for creating a disincentive. The amount of revenue raised through a user fee would be insignificant in off -setting the actual handling and disposal costs. 9. The Final Plan/EIS includes recommended actions and activities for the State to consider implementing. These include consultation and an information referral service. 10. The concept of using a common facility to collect HHW and SQG waste has been considered locally and by the State. The Department of Ecology is considering changes to the Dangerous Waste Regulations that would allow this. Currently, HHW is unconditionally exempt from the regulations, SQG waste is not. If the exemption issue and the liabilities associated with handling and tracking SQG waste can be resolved, it would become feasible to provide both collection services at one location. 5-19 RESPONSE TO LETTER FROM CITY OF BELLEVUE (cont.) 11. The survey and audit portions of the plan are designed to work with and enhance the efforts of local inspectors. This is accomplished by giving the local inspector access to a core group of individuals that have dedicated time and specific training to perform geographic surveys or industry specific audits. The audit and survey personnel will be trained on the SQG portion of the dangerous waste regulations, and in waste reduction methods and waste management options. This staff will educate and negotiate with SQGs, as well as inspect. This program, as well as the other recommended in the plan, will be evaluated on an annual basis. Modifications to the programs will occur on an as needed basis to ensure their effectiveness and efficiency. 12. Cost reflect resources estimated to capitalize and operate the program elements, based on available information. While each element was developed as independent pieces of plan components to determine effectiveness and relative cost, the final cost estimates were made for each component (i.e., education, collection and compliance). The analyses of the plan components has reduced overlap and redundancy to the extent possible at the planning level, and eliminated artificial cost escalation. This analysis is presented in Appendix A, Program Elements: Compatibility with Existing Programs and Plans. 13. See Section 3 for a description of the recommended financing and implementation elements. 1 Ll 1 1 �011� George M. Bush Seattle April 3, 1989 Page Two Department of Human Resources A system of small grants was proposed for research into innovative substi- tutions of less harmful materials to replace harsh materials currently in use. ' Convenience April 3, 1989 Convenience is considered second only to education in importance for an effective program. Each person questioned has had a personal experience in which they found it awkward to safety dispose of hazardous waste. Those who have made telephone calls for information say they have received Gregory M. Bush, Manager 9 Y conflicting advice on handling, storage and disposal. l Metro Environmental Planning 821 2nd Avenue, M/S 92 While aware and supportive of hazardous waste roundups, citizens found they Seattle, WA 98104 occurred rarely and were confused about locations, materials accepted, and safe transportation of volatile items. They felt that people would become Dear Mr. Bush: accustomed to permanent sites, and that a mix of collection sites, mobile units, roundups and assistance for the homebound is desirable. Our staff has conducted informal interviews with a number of citizens and community leaders to provide a basis for the following comments on the Suggestions relating to convenience included paying for the costs of Draft Plan/EIS for Hazardous Waste. hazardous materials at the point of purchase. Higher costs passed on by manufacturers are seen by some as the best method to ensure accountability Those interviewed generally agreed that the Maximum Diversion Alternative from manufacturers, retailers and purchasers. Higher costs might dis- should be adopted and implemented in 1990 as proposed. Some people courage the use of dangerous materials. Such a strategy was seen as suggested that public concern over the cost of this program might make the consistent with the philosophy of the recently passed Initiative 97. Phased Implementation Alternative more acceptable, but felt an increase in funding for education would be necessary for at least five years to make It was also suggested that retailers dispose of used hazardous materials. the latter alternative effective. The goal of 100% diversion of hazardous For example, auto supply stores could accept used batteries and hardware waste was seen as essential. stores might pay a rebate for an empty paint can. Those supporting this idea felt retailers could gather such materials rapidly and in large enough Education quantities to dispose of them safely and at minimal cost. Education is seen as the most important aspect of any acceptable program. Regional Approach The Maximum Diversion Alternative is most desirable because it emphasizes education of all segments of the population from small businesses to house- Planners were commended for having worked cooperatively on a draft Plan 1 holders. Concern was expressed that in order to reduce costs, planners with a regional approach. This regional approach is seen as vital in might opt for the less effective alternatives. These alternatives provide achieving a consistent regional information network. Educational programs less assistance to small business owners who produce two-thirds of the would also be enhanced and gain valuable spillover within a regional small quantities of hazardous wastes. Readers of the plan support incen- framework. tives and technical assistance to small businesses whom, in their view, have limited budgets and staff time. When a program is ready for implementation in Seattle's neighborhoods, our staff would be glad to assist in bringing interested citizens together to Reduction of Hazardous Wastes - A Priority develop plans for community education. If our Department can be further assistance, please call Anita Lammert (684-0269) or Patty Whisler (684-0270). Many of those questioned would have preferred more emphasis placed on waste I appreciate this opportunity to comment on the Draft Plan EIS. 2 reduction in the discussion of alternatives. They point out that waste reduction is the State of Washington's highest priority, and that any local Sincerely, plan should reflect that goal. They also suggest that the most economical _ wayto handle hazardous wastes is to prevent unnecessary purchase and use. � -'• I t David R. Okimoto DRO:pw:mt ... ..... ek,yv' 2-6-15776.1/2 ..,i�,i�,..nn, n,.,n�.n„nr.����.�„ivy-;�.,,;.ni.o-.haumreies•<,„dn..n,��,..�.:,uk•w.�,n�.�w�.r,,._:,,,.,,.,,r„,,,.;nwi 5-21 RESPONSE TO CITY OF SEATTLE DEPARTMENT OF HUMAN RESOURCES 1. Support for education on waste reduction and SQG technical assistance is noted. The final plan is a hybrid of the maximum diversion and the phased -implementation alternatives. It still includes an aggressive education and technical assistance component. Thirty-four percent of the 1990 budget is proposed for education. 2. Waste reduction efforts for households is budgeted at $150,000 for 1990, and will include disseminating information on specific alternative products at point of purchase to aid consumers in making products decisions. Proper waste management and reduction information for SQGs will be disseminated through trade associations, and surveys and audits. A grants program for developing innovative technology is also included. The SQG waste reduction component has a proposed budget of $758,000 in 1990. 3. A primary objective of the Plan is to make it easier for ion households and SQGs to manage and dispose of hazardous waste properly. The recommended collection programs for HHW and SQGs are designed to be convenient. Survey and focus group data indicates that most people are willing to drive a maximum distance of 10 miles to dispose of their HHW. Therefore, a network of permanent and mobile HHW collection sites providing, at a minimum, that level of service is recommended. The recommended satellite collection sites for SQG waste will increase convenience for the disposal of hazardous waste. 4. See Response to City of Bellevue letter, item 8. 5. Retailers accepting hazardous waste may be a feasible option for certain types of waste. Vehicle batteries and household batteries are wastes that could be collected in this manner. Other wastes may present more of a problem. Retailers could be required to design and build special holding facilities that meet current building and fire codes. In some municipalities, storage of these wastes would not be possible due to conflicting building and fire codes. If retailers were to accept HHW for storage, a mechanism would need to be developed to distinguish the exempted waste from others. 6. Comments noted. L 1 March 27, 1989 Mr. Gregory Bush Manager, Metro Environmental Planning Division 821 Second Avenue MS -92 Seattle, Washington 98109 Subject: Local Hazardous Waste Management Plan Dear Mr. Bush: I have read the draft of the above referenced plan and can appre- ciate the effort that went into its formation. It has been well thought out and presented in a very clear manner. With this in mind, I would like to make the following comments: Diversion Goals I believe the goal of 100% diversion over 20 years (rather than 10 years) is more appropriate. Realistically, I would expect 1 70-80% diversion to be a significant accomplishment. I think that the recycling of small containers and quantities of wastes (including paint) will continue to be difficult and greater emphasis should be placed on waste exchange, minimization, and product packaging. Household Collection Programs I believe the most realistic and cost effective program should include Q combination of permanent sites and round -ups. I think 2 mbile units would be less effective as a major tool. I further beolieve that private operation of these collection sites should be considered because of their expertise in handling, safety, treatment and management of hazardous waste. I personally think they will be more cost effective as well. I think the role of Seattle -King County should be concentrated towards education rather than operation. Subsidization of Small Quantity Generators 3 1 believe businesses, large or small, should pay their proper share of waste treatment/disposal and do not believe they should be subsidized. It is a legitimate cost of doing business. To: Mr. Gregory Bush March 27, 1989 Page 2 Financing 4 I believe a tax on hazardous materials sold in each jurisdiction should be implemented whether that be on a state or county basis. I hope these comments are helpful to you in your efforts to develop the local hazardous waste management plan. I would like to point out that I have not had the opportunity to discuss this plan with my fellow board members on the Solid Waste Advisory Board, so the opinions expressed in this letter reflect my own. Sincerely, Michael P. Keller Vice President - Operations MPK/psh 5-23 RESPONSE TO CHEMICAL PROCESSORS 1. The Final Plan/EIS does not include a 100% diversion goal over 20 years. Recognizing that complete diversion is unlikely, the plan states that the maximum amount feasible will diverted, over the life of the plan. 3. See response to City of Bellevue, item 6. 4. See response to City of Bellevue, item 8. 1 1 G 2. Cost/effectiveness analyses were conducted for permanent, mobile and Round -Up collection techniques for HHW. Round -Ups were found to be more expensive for the same level of service provided by a permanent facility. Mobile facilities may not be as effective in collecting quantities of HHW as permanent facilities or Round -Ups. They are proposed in the plan as a means of providing a higher level of collection service (over Round -ups) to areas where populations do not support a permanent facility. Evaluation of the programs over the first five years of implementation will lead to refinement of the services and improvement of their effectiveness. The does plan not preclude the involvement of private industry in service provision. Agencies implementing specific programs are responsible for utilizing the most cost/effective means. To date, private industry has been " contracted for services at the Round -up events. King County will contract with a TSD firm to provide its first mobile facility. 3. See response to City of Bellevue, item 6. 4. See response to City of Bellevue, item 8. 1 1 G Gregory M. Bush, Manager Metro Environmental Planning Division Mall Stop 92 821 Second Ave Seattle, Wa 98104-1698 Elected Representatives, Senior Management Committee Managers, Technical Planning Committee Members, March 27, 1989 Benefits for the public are significant. Our own management's expertise In re -use / recycling, facility management re -use / recycling , disposal procurement management, and safety training & contingency plan Implementation, In and of themselves, project significant positive results based on the reasonably accurate general market conditions found In surveys on which the Seattle - King County local Hazardous Waste Management plans are based & projected. We have reviewed the Seattle King Co. local hazardous waste management plan In detail. As a local firm, and representative of Based on Implementation of our effective known management the Thermal Energy Corporation Of Denver, with a corporate life procedures we have calculated and projected the following time residency In King Co. Washington, we have developed environmentally preferred results and conservation of economic management techniques, recycling, re -use mechanisms, related resources. transportation systems and procurement methods, resulting In j economic resource conservation while maintaining environmentally prioritized methods for the management and handling of H.H.W. & N.H.W. MAXIMIZATION PLAN S.O. wastes. Projected Benefits Under Effective Proven Management Systems: We have discovered slight oversights In portions of the proposed plans that should be Implemented In the Interest of the public H.H.W. Collection Component - 20 Year Period tax payers and their representative governments concerned with environmental health I. Collection Facilities 6 Disposal = ! 73,469,000 I1. Contributed Services Estimate 20 Year Value - ! 72,320,618 W!th proven expertise In respect to operation of collection, re- use / recycle, Transportation and management of smaller III. Environmental Waste Management Priorities quantities of waste and personnel training, we offer the following recommendations to the H.H.W. 6 S.O. waste maximum 46% Re -use / Recycling by June 1991 alternatives for Implementation. S.O. WASTE MAXIMUM DIVERSION PLAN Firms with established In -field expertise for the management, , handling, re -use / recycling, transportation and disposal of smeller quantities of wastes ( I.e. moderate risk wastes ) whom Projected Benefits Under Effective Proven Management Systems are wll!Ing to contribute their services In the name of local governments for I. Collection Facilities & Waste Management Disposal, Re -Use / Recycling = ! 64,637,993 ( 20 Year ) 1. The preparation, updating and/or the Implementation of local hazardous waste pians. � 11. Environmental Waste Management Priorities I 90% Re -Use / Recycling by June 1991 2. Designation of zones & fact titles to be used upon i Implementation of local hazardous waste plans should be coordinated. They should be giver. these responsibilities prioritized In the area of their Individual maximum H.H.W. PERMINANT & MOBILE abilities & e>pertlse in order to contribute planning I ( SAFCO ALTERNATIVE ) mariaoemerit to the Individual elements of the maximum ' phased, fifty percent or status quo alternatives as decided by couriel from the public Input. 1 Add broker / transporter to Increase direct availability of out of state facilities which promotes Increased accessabllity for M = M M M M � M NuW " ® M M M M I� W-' 9�- F-,_ ., t f I I F_ � = N F 2 3 M maximization of prioritized waste management activities of re- use / recycling and economic resource conservation. See RCW 70.106.160 (7), & RCW 70.106.006 (10), 6 RCW 70.106.2203 6 FR 86966-7 DEC 31, 1980 Special Note. The public Is paying for these services and has this pre-empted right. S.O.G. MOBILE & SATELITE FACILITY ( SAFCO ALTERNATIVE ) Implement a S.O.G. choice of doorstep transportation pick-ups direct to facilities, primarily out of state, without Intermediate collection or storage, thus avoiding the public and environment to unneeded exposure to literally tons of S.O.G. wastes and dramatically Increasing the avallablllty of prioritized management practices of re -use / recycling and economic resource conservation. See RCW 70.106.160 (7), RCW 70.106.220 (3) and FR 86966-7 DEC 31, 1980 Special Note. The S.O.G. Is paying for these services and has these pre-empted rights. CURRENT TRENDS The projections made by staff of representative costs for handling and disposal from local handlers and T.S.D.'s, were reasonably accurate at the time they were taken. Projections and plans however must be updated as regulatory and market conditions change. THE CURRENT MARKET TREND Chempro, a Seattle T.S.D., hes recently publicized a S.O.G. program In the Independent Business Association Monthly Bulletin describing their- S.O.G. program. This plan circumvents the Metro Mobile & Satellite plans In It's entirety. Add ItlonalIV, a cost of S 8.00 per gallon for S.O. wastes Is Leing chorged. By these facts, If the S.O.G. Mobile and Satellite facilities were put Into place, a projected Increase to the costs of S.O.G.s' would have to be added to the existing projections made under the plan. The end result for the maximum alternative for S.O.G.s' would be an additional a 296,078,016.00 or a total of f 449,769,600.00 which Is a 2012.64 per ton. These figures equlvllate to S 442.76 per barrel for the smell quantity generators. Smell quantity generators simply cannot stand for these excessive costs and the Seattle King County plan will fall. Assessing the Local Hazardous Waste Management Plan's recognition that no licensed Incinerator or lend fill exists In the state of Washington ( See Summary, Page 10 ), It should be of paramount Interest to the State, It's business's and cltlzens, that this proposed alternative be Implemented as a significant factor In safety, participation and cost effectiveness to all concerned. Of a special note, we should also consider the Inability of most local T.S.D.'s to recycle moderate risk wastes, being a significant factor In reaching the re -use / recycling priorities. Our alternative plan for transport direct to recycling facility for moderate risk wastes, demonstrates a clear and positive alternative which best exemplifies and promotes the King County reuse / recycle program. In ere y i nes E. Johnson aside t, Safco Environmental 5 I1, Environmental site impact necessities for mobile or 5 Significant factors concerning legal Issues and potential _ate lite site would be ellminated es the potential Impact, barriers elevlated by Safco Environmental Plan erivlronnrientally, would be alleviated by the fact that these sites would not exist. 12. Fees fund 1. Technical recommendations are eliminated as recycling Is to this program should only come from S.O.G. performed. business that generate S.U.G. waste. a. Targeted Industrlea should pay for Increased garbage and 2. On site verification of S.O.G. status Is available by sewer surcharges. Inspection of qualified brokers who do not want to Illegally b. Theseaccept Individual S.O.G. businesses should be alleviated regulated generators as conditionally exempt from this surcharge If they participate In an ongoing generators. recycling program subject to spot Inspections by the health department. 3. Cercle liability Is eliminated as the targeted waste streams C. In are detoxltled when recycled or liability assumed by the this manner, non - hazardous waste generators are not legality of transport recycler. negatively affected by the S.O.G. who does generate wastes and the S.O.G. who participates fully Is not affected by the S.O.G. who does not. 4. D.O.T. transportation concerns are non existent for S.O.G. d. ThIs also reduces the every day citizens tax burden as businesses as the broker / transporter assumes them. Lost associated. S. Site selection difficulty Is eliminated because selection 13. Page 1-11 paragraph 3 discusses the role of local U.S. state sites are not needed. in S.O.G. arena. By changing WAC 173-303-070(8)(G)(c) to read 6. Known costs of disposal exist and subsidies can be assessed (c.) Permitted ...... . Out of state,wlth written permission if needed at all. of that facility : or this would mean that the S.O.G. would be unable to dispose of dangerous waste In the sewer or public landfill. 7. S.O.G. will be appreciably more willing to accept significantly lower costs by facility direct recycling vs 14. EFFECTIVENESS: paragraph 3 of page 6-16. ballooned expense via collection facility and local T.S.D. facility cost add-ons; which are In many cases un -affordable Ac- effectiveness via costs and performance are a significant by S.O.G. small business. - Gue as stated, It seems appropriate that a cost effective pr ogran-, with proven high performance history would pre - B. Profile costs are less expensive out of state and can be alleviate higher cost g potential and program Ineffectiveness preformed at a minimal expense If done by a S.O.G. qualified t:nk_nowr:, before their unknown systems are implernented, broker at no or little excess expense or trouble. As evidence, our cornpany Is Involved with the recycling of dry cleaner's waste using the suggested alternatives above rec:AItIng In a 66% success rate over 2 years ( per Yerkes g. Dedicated funds for satellite or mobile collection Aral• 1£x86 ). Thus living pruof ( See page 2 - 29 1st facilities need only be loaned to broker / transporter, as r h ) that this P;'r.ai aG planned alternative exists. profit Itself Is reasonable enough to repay taxpayers money. W, - h assessed the budget and based on the previously noted ;r—, found that tl.e local ta, payers and small quantity 10. With lower Disposal costs, the subsidy of 26X can be r aloe=_ w•uld be paying an estimated $200,427,611.00 in Increased thus positively Influencing S.O.G.'s desire to rer,Cle their wastes. M M M M M M M MM MM M MM MM Mililm., MMJ M 5 e—uss funds based on our real world experience In this market vlth the react same target S.G.G. groups. Approximately 90% of the wastes can be recycled at R.C.R.A. authorized facilities through out the nation thus bringing Into compliance local governments of the state's law, R.C.W. 70.105.160 with the second highest alternative " Recycling " and the purpose of WAC 173-303-010(7) encourage reduction, recycling.... to the maxlrnum extent possible. 5-28 RESPONSE TO SAFCO ENVIRONMENTAL/THERMAL ENERGY CORPORATION 1. Safco HHW Permanent and Mobile Alternative. In conformance with the State's hazardous waste management priorities, the plan places major emphasis on waste reduction through education and technical assistance programs. In addition, collection programs targeting wastes such as used motor oil, auto batteries, household batteries and paints emphasize recycling. Recycling of hazardous waste is the second tier in the State's management priorities. The plan does not preclude involving private industry from providing collection and recycling services. Agencies implementing specific programs proposed in the plan will utilize the most cost/effective techniques for providing services. 2. Safco SQG Mobile and Satelite Facility Alternative. Any facility operating under Federal and State laws to recycle, treat, destroy or dispose of hazardous waste is eligible to provide such services to the SGQs addressed in the plan. One intent of the plan is to encourage the hazardous waste handling industry to develop options for the proper management of SQG waste. A transporter meeting all applicable Federal and State laws that proposes to provide doorstep service is not precluded by the plan. 3. Current Trends. Projections in the plan for waste generation, reduction and collection, and their associated costs are based on best available estimates at the time of plan development, and are subject to change as regulatory and market conditions change. Budgets and waste projections will be updated annually based on program evaluation data. If implementation experience shows program costs to be substantially lower than projected, budgets would be adjusted accordingly. If implementation costs are higher that projected, programs will be modified, the goals for waste diversion will be scaled down, or budgets will be increased over plan projections. 4. Current Market Trend. Chemical Processors, Inc. (Chempro) has developed a service for SQGs, providing another option for the management of this waste category. This is consistent with the intent of the plan. Chempro's service does not increase the cost to all SQGs. Generators (including SQGs) select the service that best meets their specific needs. No generator is required to use this particular service. The plan does not identify specific TSD firms to provide services for either HHW or SQG waste collection. Services bw mt RESPONSE TO SAFCO ENVIRONMENTAL/THERMAL ENERGY CORPORATION (continued) and facilities that can most cost/effectively be provided by private industry will be competively bid by the public agency implementing the program. 5. Significant Factors. 1. Technical assistance will promote waste reduction as well as identify recycling opportunties. 2. The plan does not preclude brokers or TSD operators the opportunity to verify SQG status. The plan encourages the development of additional services for SQGs. 3. and 4. The liability of the generator of hazardous waste remains until the compound is destroyed or significantly altered. The generator is concerned with DOT regulations as it is liable for any damage caused by the waste during transport. 5. Safco's proposal to provide door-to-door collection service for SQGs expands the options available to these businesses. The plan proposes the development of mix of collection options which includes mobile and satelite facilites. These facilites will require sites on which to operate. 6. See Current Trends response regarding projected costs. See response to City of Bellevue, item 5, regarding SQG subsidy. 7. and 8. The plan encourages the development of private waste handling options for SQGs. A greater number of options on the market should promote competive pricing of services. 9. Dedicated funds for the satelite and mobile collection facilites would pay for staff and equipment to run the facility for a limited period of time. If the facility is profit-making, the operator may be required to assume all or part of these costs. These funds would then be reallocated to another SQG program. 10. If implementation costs are lower than projected, the program could be expanded, or funds reallocated to another program experiencing cost overruns. This decision would be made by the budget -authorizing body, likely the King county Board of Health. 11. See above, Response 5. 12. Funbu ding of the SQG programs will be generated from fees levied on commercial and non-residential accounts of solid waste and wastewater utilities. These fees will not be 5-30 RESPONSE TO SAFCO ENVIRONMENTAL/THERMAL ENERGY CORPORATION (continued) levied solely on identified SQGs, rather they will be spread among all businesses as a cost of managing waste in the region. The HHW program costs will be spread among all residential accounts in the county. Some households and businesses may not directly use hazardous materials and generate hazardous waste. However, most if not all use services that generate these wastes such as drycleaners, automotive servicing and printing services. Similarly, the City of Seattle solid waste recycling program costs are reflected in all its residential accounts, not just in those participating. These programs benefit all businesse and residents in the region. Fees based on tonnage (solid waste) or gallonage (wastewater) will serve to promote general waste reduction and benefit those who produce less waste. 13. The State Department of Ecology is currently reviewing WAC 173-303-070. Section (8)(G)(c) may be changed if the State determines it is beneficial to waste management programs and the environment to do so. 14. The awarding of contracts for waste management services will consider demonstrated cost/effectiveness in implementing waste management priorities. If recycling and treatment are more cost-effective than other waste management options, and promote the State's waste management priorities, it is likely these methods will be favored in selection process. 1 2 3 4 ` The Mountaineers „ail iur,�l .:,�nu�•Wr.d • 'cattle. VJa:.hultllun 118110 • 120612846310 •,1., t , t tit 11 ut r6U9A AMO till IN(JIA41 March 29, 1989 Gregory M. Bush, Manager SEPA Responsible Official Metro Environmental Planning Division 821 Second Avenue, MS -92 Seattle, WA 98104-1598 RE: Draft Local Hazardous Waste Management Plan Dear Mr. Bush: As the largest conservation and outdoor organization in the Pacific Northwest, The Mountaineers' 11,000 members are deeply concerned that hazardous waa;tes be managed in an environ- mentally sound manner. Hazardous waste, regardless of its source, needs to be rendered inert to avoid any possible harmful impacts. The Local Hazardous Waste Management Plan for Seattle -King County Prgvides several options for minimizing those impacts due to household hazardous wastes and small quantity generators in the business sector. Currently, there is not an acceptable strategy in place for managing these wastes. The Mountaineers, as concerned citizens, realize the respon- sibility of safeguarding the environment for future generations. In light of these concerns we find that the 508 Diversion and Status Quo alternatives are unacceptable. We cannot afford the future costs that the neglect and mismanagement of these wastes will bring in the future. our past experiences must guide our future practices. The remaining two alternatives provide a well -thought-out course of actionfor eliminating the maximum amount of hazardous wastes from the waste stream. The proper handling and disposal of these wastes will pay dividends well into the future. In meeting these goals a variety of approaches need to be implemented. Programs emphasizing hazardous waste reduction through environmentally sensitive alternatives and practices need to be given the highest priority. Recycling and exchange of these wastes also contribute to cost effective management. Treatment and disposal options should be the last resort method in dealing with this problem. Existing transfer stations should be considered as sites for this part of the approach. Legislative efforts need to be undertaken to assure that the cost of hazardous materials on the open market reflect their inherent disposal costs as well as those of production. we need to be reminded that there is "no free lunch." The Mountaineers heartily applaud this hazardous waste management effort. Everything possible must be done to ensure I,. 1 >111 0,1 1111. 1111 :,I Wit Atli) I N.tt1Y 7111 NA10"At HCAUTY UC Tilt- NOliTHWCtiT Gregory M. Bush, Manager March 29, 1989 page 2 its implementation and success. As citizens it is our respon- sibility to ensure that our unique quality of life is enhanced as the region continues to grow and prosper. Thank you for the opportunity to make these comments. Sincerely, THE M-ODUNTAINEERS C-4/T,✓1-tr�� Carsten Lien President CL/n1 cc: Rodney Hansen, Manager King County Solid Waste Division Richard Yukubousky, Manager City of Seattle Office for Long-range Planning Diana Gale, Director City of Seattle Solid Waste Utility John B. Lampe, Superintendent Office of Water Quality Municipality of Metropolitan Seattle 5-32 RESPONSE TO LETTER FROM THE MOUNTAINEERS 1. Comments Noted. The Final Plan is a hybrid of the Maximum Diversion and Phased Implementation alternatives presented in the Draft Plan/EIS. Programs are designed to divert the maximum amount of HHW waste feasible within a 10 to 15 year timeframe, and 15 to 20 for SQG waste. 2. The plan will promote the State waste management priorities; waste reduction and the recycling of targeted wastes will be pursued by education and technical assistance and through specially -designed collection programs. 3. The City of Seattle currently operates a HHW collection facility at its South Transfer Station. Other existing transfer stations will be considered during specific site selection processes. 4. The Final Plan/EIS presents recommended actions to be considered by the State, including a local add-on to the State Hazardous Substance Tax. This would place part of the cost of plan implementation directly on hazardous substances. See the Section 3 discussion on "State Role and Recommendations for State Action". A1d1ANLE FOR SOLID WASTE ALTERNATIVES 5) The Interagency Comtittee approach to dealing with household 1414U - 56th Avenue South hazardous waste and small quantity generator waste should be 'Baxwila, Washinyton 98168 continued since it brings together the expertise from Metro, the Solid Waste Departments and the Health Department. Such a group should monitor the implementation of the preferred alternative and initiate a public process for any proposed future changes of March 27, 1969 the Plan. Gregory Bush, S1PA Responsible Official IA)cal Hazardous Waste Management Plann Metro Environmental Planning Division MS -92 821 Second Avenue Seattle, Washington 98104 Dear Mr. Bush; The Interagency staff front Metro, Seattle Solid Waste Utility, Seattle• -King County Health Department, Seattle Office of Long Range Planning and King County Solid Waste Division have initiated an excellent planning process for handling hazardous wastes from households and small businesses. The Draft Local Hazardous Waste Management Plan for Seattle -King County offers a full range of well developed alternatives. Our contents on the Plan and its alternatives are as follows: 1) We support the Maximum Diversion Alternative which has a goal of reducing the amount of hazardous waste generated by the 1 household sec. -tor by 43% and diverting 10U8 of it from disposal in the Metro sewer system or the Cedar Hills landfill. Hazardous wastes from smell quantity generators under this scenario would likewise be reduced by 228 and most would be diverted from improper disposal by 2004. 2) Wt: realize the cost of this alternative is staggering. However, the cost of continuing with the status quo is also enormous and should be included in any further discussion of 2 alteratives. The most equitable financing of the necessary programs is through a tax on household products that contain hazardous substances. This incorporates the cost of disposal in the price of the product. 3) 'Phe emphasis in dealing with household hazardous waste should be on education. EL-uc:ational efforts should stress alternative, less toxic products and all ropriate disposal practices. 3 Collection facilities should also be available to the public either at transfer stations or existing TSD facilities. If space at King County transfer stations is unavailable then the County should invest in mobile collection units. 4) Waste audits should be enjohasized for small quantity 4 generators. kdUCatiional materials can be developed targeting s[.,cific industries which describe successful product substitutions or changes in a manufacturing process that results in a rexluctiun in the toxicity and quantity of the waste residue. Thank you for the opportunity to make comments on the Draft Plan and EIS which is an excellent first step in local comprehensive planning for hazardous waste. Sincerely, Alliance for Solid Waste Alternatives By: Gabriella uhlar-Heffner (206) 632-1545 Alliance for Solid Waste Alternatives Member Groups Black River Quarry Coalition, Tukwila Citizens Alert, Skagit County Coalition Against Incineration, Spokane County Citizens Against Incineration, Snoqualmtie-Preston Environmental Task Coalition, Cedar Hills Area Greenpeace No Dump, Cedar Hills Area Norpoint Coalition, Tacana jResidents Against Trash, Redmond Safe Waste Management Now, Watoom County I Soos Creek Action Alert, Auburn Puget Sound Group, Sierra Club Washington Toxics Coalition 5-34 RESPONSE TO ALLIANCE FOR SOLID WASTE ALTERNATIVES 1. Comments noted. 2. See response to The Mountaineers, item 4. Plan funding is detailed in Section 3, Financing. 3. The Final Plan/EIS proposes mobile collection facilities for HHW. King County is currently working on the development of the first of these units. 4. Waste audits for SQGs are proposed in the plan. 5. Section 3, Implementation, outlines the proposed regional interagency plan implementation strategy. r r r r r r r rr r rr rr rr rr �r r r r r r LEA1.12onnty C111zens f.n- ResponSlt•Ie WaSte M—aQV:nc•nt ... .. Comments s on the LOCAL. HG, ARItOLIS W:ZU FLAN FOR SEATTLE--VIWG COLINI 1 Draft Plan and Environmental Impact Statf-aic-i Februe, y 1989 i I �, �. 1.1,E ,t• � , i �� I�� I � �..nuu...t Fi .�� i 1..1� � n1� i',,.t i .. f.�. R.,..:F�I•��,:�,hi.... ( ..I.. i. on tht Lift4A I; -.'.d l ir_r,. ;f, -•_'U I -t .,(1 1`44. 1 Ir.. iuil,i � .r. t r .., •,�.[ t-,,.,, .�, •, ., :.I l,.,h� I it .. t. ri�„,. ,. t.. 1 i � � i �� -I I I. .I.t.. � tn�., t �,. �. �.•, �� ��'l ,� , t t,. . .. ..:.I , n „r, .. i � ��„ I I I. t. �� l i .1•t . I t l:l. : 1.. t. Ana �. _ i.•1 .I �.,��i.....,1 I•.1.�.. 1,•...-I�..-•t:1. It, il�. I I h- I ' --d ;.f-•',•-I�n.)ei<•n:�,.i,..,,., ,�I c_L. ,.1 r. �,Il•:.;., Fo, .� t t t � .� .-,"vv � Cwt•- - L'z•-- R•.•�_.p-, -: i K l e WQ•:, ate 11::rn,"ge.e. W Overall Approach: The various agencies are to be applauded for cooperating on this effort. The overall approach of the draft plan and EIS seem=_ sound and reasonably thorough. A reasonably wide range and diversity of specific elements for reducing the amount of small quantity hazardous waste reaching the environment are analyzed. However, the four constructed -alternatives derived from these elements do not adequately nor accurately reflect the most effective and/or efficient ways in which hazardous waste can be controlled using these elements. This must be corrected in the final document; specifics are given below. Also, the manner in which the analyses of alternatives are presented in the draft plan are, in part, misleading, and certainly not optimum for informed decision making. This must be corrected 1n the final document; specifics are given below. Comments on Summary (references are to page numbers in the Dtaft Plan and EIS) S-12 et al The scales are not the same on figures showing HHW and SOG tonnages for each alternative. This is misleading to anyone 1 co mparing the effectiveness of these twofoci of the plan, and may"t lead to poor analysis and decision making. All comparative fin--. should use the same scale. If this will make the HHW figures too small for legibility, they may be blown up, but still to a physical size smaller than the SOS figure, and a prominent note placed calling attention to the difference in scale. It would also be helpful to put tonnage amounts snider the labels for each area iu the figures, regardless of the scales used. S-14 et al 2 In thecc.st tables, total 20 year cost and cost per ton diverted should be include for the separate HHW and SOG elements of each alternative. S-23 Comparison of Alternatives This section needs major revision. First, our comments above relate to leepina separate the aoMys_es for HHW and SOG, and showing their cumulative costs and 3 effects. We feel this is critical for choosing the best plan for dealing with the total small quantity hazardous waste problem. Since SOG is 2/3 of the total tonnage, and since the plan shows every dollar spent on SOG control may have more effect than a dollar spent on HHW, it is imperative that the majority of effo,t go toward SOC programs. This is not the case under any of the alternatives presented in the draft. 4 between Ma;:imum Diversion alternative shows an approximatit balance dollars spent on HHW and SQG, with considerably more to.,s of SOG being diverted. However, the problem being addressed in the l,lr„ I i,.._t.nl. .]Ie,l ..try of woc-tr_ Irmo thr t— ir.. .,,... ,.t tw_t._, 5 r,I 1 df 1 11) 1ht wt•t f'' •1 n nn , e ) .for 1 ,e ---1 , _ w• I•, of it„ t... Ilbt--r1 ttl.rS •tI'. ., 1 t r•r n� 1 t vc. (h.n T•. t, le 1 shows this.. alysts. 'iou cam., se•e tl,rt t, It, 11,c• n,a:. iml un c,nd phased 'HHW alternatives '(and even the 50% �•l.r_rnativa) -.-e a s "effective" as the ma>.tmum SOG alterr.rtie. .;1 so, the "efficiency" of the ma:,imun, SOG alternative does not even approach that of either the maximum or phased HHW alternatives. A tat:,le such as our Table 1 should be presented tr. the plan summary (and eleswhere as appropriate). Second, in the current Phased alternative (arid the 50% alternative as well) SOG programs are cut back: much more severely than HHW programs. This is backward from what ought to tie done if the Ma,cimum Alternative is not implementable. Thus. an alternative including r,rc,grams for maxtmun, diversion of SOG Coupled 6 witr_an HHW _program level similar to phased diversion c•r the fi,_ t fi.,e�ears of 50 diversion, should be included in the plan. It will have less cost than the current Moximum Diversion alternative, blit cor,_iderablVmore effect than the current Phased Alternative. DrSlC�lll'(ICI_c. *,,E•,l more intensive ma%•tmculi SOG proglre, mr•f als.n bE- Z,E:tif�E-d. 1," teiu,s of the total art,oui.t of dongeroos wastes wl,cch Slip by into the landfill or water. we lose only a little by dr-'layirlg HHW programe, but we lose a lot if SOG progl amE, ane delayed or pursued less vigorously. 5-24 ClUOVlative CC-Sts for 20 years should be shown) in or ad,iace,-.t to Figure 10. 7 S-25 The fir,a,-,cing analysis looks c•nly at 1990, a highly ar6c,nial0us year. This must be changed. See full discussion at comments cri Section 5-3. below. m=== m== i== m m m= m s G4accf„ e f Icicncy , tons cost/ton tons tans missed/ dvrtd 20yr (last) missed $mill. spent HIiW max 137,655 $ SB3 (755) 32,723 269 phased 100,857 $ 924 (757) 69,521 746 50% 51,995 $1012 (795) 118,383+ 2,250 status quo 17,724 $1653 (1633) 152,654+ 5,210 506 max 223,467 6 387 (254) 117,289 1,357 phased 142,085 $ 480 (252) 198,671 2,912 50% 71,409 $ 401 (128) 269,347+ 9,408 status quo 1,062 $3781 (3042) 339,694+ 84,501 m=== m== i== m m m= m s M M i M i M M � M M M M M M M M M M M 8 rU„Ir a sl,nr gc•el cen tit'- eccof. tat. It f I r„y Co rt., lfr, . t•ill.'e, It Ha:lmum or Phetud aIter ,..tive (or a n,•thc•, de--crlticd ebovcr should ti_ Fit efer„ed. HHW CIII I&L t l C•r, A ml:: of permanent and mobile collection sites, targeted plck:up, arid roundups should be used (see commeryts at 3-11 and 9 trleswhere). A diversity of options will maximize participation. KC should not ptit all its eggs in one baslet, and should remain open to new ideas! (p.s. We feel the draft plan does a reasonable joh of l.eeping with this phi losphy). SOG Sub= -idles Frc•per disposal s1-rould, ultimately be a cost of doing business; all programs should be designed to lead to this. In the interim„ direct subsidies in order to facilitate proper disposal may be 10 apprc•priate. Businesses should not be encouraged to become dep,_ndent. on SLdisidies, howe,er, nor should the subsidy progr amrs i „tEl fere with development of collection, recycling and disposal eervices by the private sector. Edi,(.atic.— audits, reference info, etc. will reflect a e„t-stantlal, continr,ing se,bsidy” by governmFnt, of course. (p.s. the same aegcntenta apply to HHW as well.) F i nano i ng Every effort should be made to avoid charges which will discc.in'age proper disposal. Ultimatley, this means shifting all charges to the point of purchase; this will also encourage use of 11 non -ha.: ardaus pr-o•ductS. In the interim, a n,i;t of product tares and waste handling or disposal fees is appropriate. We do not see noroiral charges at collection points as seriously limiting participation in hazardous waste programs. Fllease note the comments or, deciding finance policy at 5-7. Local vs. State Both state and local educatic•n of SOGs is apprc,priete. The key is, I:Ing COUrity should not wait for state action, hC is 31% of the state (and perhaps more for such purposes); this is more than 1 >ufflclent cic,ut to work: effectively with business groups, trade associations, and large arid small businesses, and to set tip”) our own programs. We should serve as a model for the state, not welt for the state to take the lead. AdmiIII St. ation See comms --its at 5-12. A mis=sing ley issue: Alternative to be Adopted We feel that a Manimum Diversicnr alternative, augmented to increase SOG diversion, is the most appropriate. If this is Trot feasible, a hybrid alternative as described et 5-23 above, is 1 3 tthe i,e s,_cood prefe-,eoce. Anything with lass impact' on waste re,chtny 3 environment, we Would consider not acceptable. Also, _action 3-1 states that one of the four alternet.ive� i„ il,e draft will be selected as preferred in the final plan. this is riot the c..aswt Policy makers and the puUlIc mush have the f-t—j--t. In fart he encouraged, to de-elnF, alt-rnatrv,- er­„ . ins using the lr,foo ntaticn in the ch'aft a,i ptesented at the hear inU�. Tt,e_ Efevrred i+llr�rriet_ivE_ln Me. flhal OV, 51.(•Uld rrflrct�tt,c• b,t:•st cI. -r t_nt tt1 Il lil,�thl may be, Gut is not limited tI, ,e_of the g1 te, .at ive sce„a, ices In thi-draft. [,1 ait. comments on Section 2 2-9 Are more recent tonnages and projections available than the sources cited? Would updated numbers change the analyses in arty 14 material way? Short answers to these questions would help assure that the problem has not changed with the onset of recycling programs and decrease in disposed waste seen over the last 9 mouths in the county. 152-14 Figure2-5 It would be helpful to include a similar pie chart for SOG wastes. 2-28 Since 60% of garbage is not self -hauled, that 60 of H11W in the waste stream comes from self -haul may show a high reluctance on the 1 G part of individuals to throw haa. wastes "in the trash". Has this V been fully factored into the programs proposed in the plan, and they potential acceptance and effectiveness? The high volume of HHW in self -haul may also reflect use of transfer stations by SOGs. Has this been explored and factored into the plan, especially ramifications for transfer station operation and load inspection? 2-29 Is the plan perhaps underestimating the potential for SOG waste reduction and collection, given the rapid success of the (rion- 1 governmental) effort to properly handle dryclear,ing wastes? What were the pressures which have brought about this change? How can similar pressures be brought to bear on other types of business" The plan should explore these questions and use the answers in designing and implementing SOG programs. 182-36 Table 2-16 does not list private TSD ar,d related facilities. The appropriate list should be included in the final plan. 19 The ideas from SOG focus groups should be given high credence. Use of trade associations to bring about waste reduction and control should be given high priority. 2-5Jon All of the recommendations for state legislative action seem very good, and should be pursued. but some of these can be pursued by Karig County unilaterally, and should so be dome until state action occurs. See also comment at 5-4 on local tar, cm cor,sun,er products. CC -0,11 1 1— , 1 Ilii _i 3-1 -•.•. coaw.er+t, o++ de•veI,plug -nd choosIrig :Itk•. vicat I I& at: Se•:.tr, 1, lte-.sJng Ley , otuWk-. 3-2 Table. 3-1 Policy ii—IA—) would be better served if tons diverted and remarng in the wr_te stream were separated by HHW arid SCIG. 3-11 Wo suppc•+ting data to justify dropping round -ups is presented 20 (here or anywhere else in the draft plan). Given their existing pc.pularity and success, I.epping round -ups (at least initially) in ccnlikinction with the ether HHW collection orc•grau+s, would seen, k+r—Se . Also, our calculations from the data presented in the plan indicate round -ups are about equally cost effective as the overall HHW programs in the plan. 3-15 21 No supporting data is included in the plan to show pickup as being "prc•h3bitively expensive". 3-15 Lhar.gieig e::emptions for only some SOGs should be explored. Was 2 n this perhaps_ c•ne of the pressures causing dramatic change in the. L drycleanivg industry? We do not believe this option should be dismissed nut -of' -hand. 3-17 oo figures 3-1. 3-2 etal Pleaee a=_e the same vertical scale on HHW and SCIG charts and diagrrms. (refer to full discussion ire comments on Summary above.) 3-22 on Tables 3-5, 3-6 et al Separating "neissed" tonnage Lnunicipal disposal) from "I nowledgeably disposed" tonnage (collection and disposal) wc•uld greatly facilitate under st and i reg and review of the plan. 3-23 2 �i Weed HHW collection be ruin by government? Operation by TSDS or J other private business should be e;:plcn-ed and costed ire the plan. 3-47 Figure 3-10 The bottom band is not labeled. The second band also seems neislabeled. -51 Iasi paragcaph HHW stc•uld be removed in the title before Status Duo. Dollar signs need to be kdded as appropriate. 3-52 Table 3-13 Thc� number fc•r SCIG Accumulated Menu cipal Disposal does oc•t coo,pr+te from data ire the Appendi;c. 7th15 should be rectified. cc•mmeots un Sec tt i•.•ii _v 4-c2 2 The relative environmental costs of less aggressive HHW versus less aggressive SC)G programs should be clearly and proms ner•tly discussed. 4-3 Tables 4-1, 4-2- 2 The waste entering the environment should be separated by HHW and SCIG. (refer to comments and our table in comments c,n Summary, above). 4 26 A reference is made to the environmental health risk analysis. What is this and where (when) is it? 274-12 fourth paragraph The first sentence would better read: "Alternative transport: routes would be evaluated as part of the process of identifying collection sites". Surely the sites should not be identified before transport is considered. comn•eerts on Section 5 5-2 2 A A priority from the superceded Hazardous Waste act is {XJ irrelevant. Please eliminate the last sentence in the paragraph Descriotic•n. 5-2 Could some remedial dollars be used to fund programs in this 29 plan (such as SOC audits, for example)? this possibility should be euplored. , I 5-3, 5-7 on Tables 5-1, 5-2 et al The cost analyses use only first year revenue projections, which are highly skewed compared to later years. For example, over 20 years king County's share of Local Toxic Control Account will be $2.38 million per year, not a.92 million! The analyses and tables also are only for the Maximum Diversion alternative. Rath costs and revenues change dramatically in later years and with other potential alternatives. This should be reflected in the financing sections. The analyses and tables shcaild be rethought and reworked to show projected revenues and cost allocations for the first five years, and every fifth year therafter, and total 20 year planning period. The chosen financing Structure will not likely charge each year, and thus should not be based on .fust one year's arialysi.e. especially such an annmalC•US year as 19941. 5-4 Car• k;iny County unilaterally put a tax on consumer purchase of 30 hazardous mklteri'Is? This would be separate frc•m the add-on described in the plan, and raise considerably more money. This option should be explored ire the plan. M M M M M M! M M 1 4 M M M i M®® M M = M = M = = M M 3 ■ is th. P. tW4 In ME WO In"ea_c pr- n•.—M?PMye", 7 • Thv stated = HHW - % SOS split is incorrect. It is actually 477.-53% for the first year, and then changes to a prepoderanc" for HHW. 5-12 3 In our Opinion, only the Management Committee or Lead Agency would seem viable. Either will also require interlocal agreements. comments on Qnpernjdir. A A-18,19 Round -ups Disposal is given a single dollar amount. This should be a cost per ton, as it is in the other program elements described. No total cost/tum is given, yet this element is eliminated from the scenarios (eNcept status qua) based on cost. A uniform cast/ton co(ihe_rl_-on should_be provided for. this ort•gram e]emeut -nd all other s At $6621ton disposal cost (see comment at B -I5 below), it represents AR3 tons, for a total program cost of $12637ton. This comparahl a to the costs cited in the draft plan for ether HHW collection alternatives lfor insta ce at S -I5). The discussion on A-19 is a strong argument for (at least 33 initially) continuing round -ups, regardless of which alternative set of programs is chosen. comments on Appa"di% B B-12 Refers to the draft Programmatic EIS. A note that the final saw no significant change in tonnage estimates (if true) would be, reassuring. B -I5 The cost for disposal of an average mired waste lot is show. as 3 4 $681.59/ton. This is quite different from the $1050/ton cited at B-13, and apparently used in cal"Oetions in the draft plan. This discrepancy most be rectified, including being sure all analye.es in tho ply win based upon comparable calculations. 8-15 35 Points 12 L 13 highlight the lag time in SOG program effect. This argues for immediate maximum SOG programs, even if HHW must then be delayed. U-15 Point 14 is confusing. Are some words missing^ B-15 Point 16 has a word repeated. B-22 216 Wo money included for plan updates ire 1999, 2004 and 2"OQ . Should this not be included? B -c7 3 7 compthe rows HHW Generated Collr_•ctioro Gc•el/HHW Collected do not ute. This should be rectified. and any changes carried through the spreadsheets and analyses. B-27 3 Costs for two collection sites are shown for 1989, but not Elincluded on the Program totals. Are these already funded? If not, their costs should be included hese. B-27 3 9 It is not clear if costs for mobile facilities include handling UVJ and dispc•sa" This should be clarified. B-29 Cumulative 1990-2009 totals for all rows (tonnages and $s) should be given. B-59 ditto B-73 ditto 5-40 RESPONSE TO LETTER FROM COUNTY CITIZENS FOR RESPONSIBLE WASTE MANAGEMENT 1. Every attempt has been made to use consistent scales in figures in the Final Plan/EIS to show comparable information. Where this is not possible, notation is clearly made on the figure that the scale is different. 2. Tonnage amounts have been added to the appropriate figures. 3. The summary of the Draft Plan/EIS did not present the level of detail suggested in your comment due to the number of alternatives discussed. The summary of the Final Plan/EIS does provide a greater level of detail for the plan. 4. The Final Plan/EIS presents separate analyses for the SQG and HHW components, as well as their financing and budgets. Note that the SQG component costs are only for those publicly -sponsored programs and do not reflect total SQG waste management costs. Most of the disposal costs will remain a private -industry cost. Therefore, the total cost for SQG waste management is substantially more than the total program cost for diverting household hazardous waste. 5. Table 4-1 provides information on the tonnage of local hazardous waste projected to enter the environment and the municipal waste streams. 6. Conceptually, the plan is a hybrid of the maximum diversion alternative and the phased implementation alternative presented in the Draft Plan/EIS. The SQG component projects reaching its goal of maximum diversion feasible in a timeframe closer to the maximum diversion alternative. This reflects the importance placed on managing this waste stream. 7. Appendix B shows the cumulative costs for the plan over 20 years, although budgeting emphasis is on the first five years of plan implementation. Substantial evaluation will occur during the fifth year which could result in revisions to the programs and consequently their budgets. The 1990 budget is detailed in the plan as in most cases the implementing agencies have identified 1990 programs and budgets. This provides a baseline or the program level currently committed to. Financing for the first five years of the plan is shown on Tables 3-5 and 3-6. 8. The plan is projected to divert the maximum amount of local hazardous waste feasible; accomplishing this within a 10-15 year timeframe for HHW and 15-20 years for SQG waste. Although 100% diversion is the ultimate goal, it is 5-41 RESPONSE TO LETTER FROM COUNTY CITIZENS FOR RESPONSIBLE WASTE MANAGEMENT (continued) unrealistic to assume that at some point within the planning horizon, every amount of such waste could be diverted. 9. The plan proposes 6 permanent collection facilities and 3 mobile facilities for the collection of HHW. 10. See response to City of Bellevue, item 6, regarding the ' SQG subsidy. 11. See response to City of Bellevue, items 7. and 8., regarding financing. No 12. The Final Plan/EIS includes a major education effort for both households and SQGs to be implemented on the local Is level. 13. See 6. above. 14. Tonnage estimates and projections are based on the most current, reliable base data. 15. See Figure 2-5b. 16. See 14. above. of 17. Metro's Industrial Waste Section and the Seattle -King County Health Department have been working with targeted industries to encourage appropriate hazardous waste management and disposal practices. These efforts have been assessed and incorporated into the plan's SQG programs. 18. Table 2-10 referred to in the Draft Plan/EIS was omitted by mistake. It is not an appropriate function of this plan to identify and perhaps seemingly promote private hazardous waste management firms. 19. Input from surveys and focus groups has been used to design the plan's HHW and SQG program elements. 20. Analysis of using Round -ups as an effective means of collecting HHW shows them having greater cost for the same level of service provided by a permanent facility. Part of this analysis is the convenience factor for the user, as well as site operation. Permanent and mobile facilities will provide a more cost-effective, convenient and safer operating mechanism. The effectiveness of permanent and mobile facilities will be continually evaluated. 21. Appendix A describes door-to-door pick up service in detail. 5-42 RESPONSE TO LETTER FROM COUNTY CITIZENS FOR RESPONSIBLE WASTE MANAGEMENT (continued) 22. Hazardous waste regulations are set by the federal and state governments. The purpose of this plan is to develop and implement programs for managing wastes to comply with such regulations. As specific regulations appear to warrant change or modification, the participating local governments will work with the appropriate regulating agency to advocate those changes. 23. Implementation of specific programs will be done in the most cost-effective manner. The plan does not preclude the use of private operators from providing collection services. 24. Environmental costs associated with inappropriate disposal of local hazardous waste is not readily available. Section 4 discusses landfill clean-up and closure costs that have been affected by unacceptable levels of constituents in the soils and groundwater. These levels can be, in part, attributable to the disposal of HHW and SQG waste. The precise level cannot be computed, however. 25. Table 4-1 separates waste entering the environment by HHW and SQG waste. 26. The environmental health risk analysis is presented in Section 4. 27. Transport and access to a potential collection site is one of the criterion used in site evaluation. 28. This plan is guided by WAC 173-303-070, the current State Dangerous Waste Regulations. 29. The current allocation of the State Local Toxics Control Account has specific line accounts including Remedial Actions, Local Hazardous Waste Planning, and Plan Implementation. Funds allocated from a specific line account must be use for that designated purpose. The plan assumes the Local Toxics Control Account will provide 31% of the implementation budget. 30. A local jurisdiction cannot unilaterally impose a sales tax on consumer items. Appropriate legislated procedures must be followed. 31. The projected increase in Metro sewer rates is based on $.16 per month per $1 million in Metro's wastewater treatment operating budget. The projected increase in Metro's rates can be found in Table 3-7 in the Plan Description section. L 5-43 RESPONSE TO LETTER FROM COUNTY CITIZENS FOR RESPONSIBLE WASTE MANAGEMENT (continued) 32. Section 3, Implementation, outlines the proposed regional inter -agency implementation strategy for the plan. 33. Disposal costs for Round -ups are higher (reflecting different waste handling contracts currently in effect), as are handling costs. In 1988, handling one gallon of waste at a Round -up cost $7.35, while the same gallon handled at City of Seattle's South Transfer Station cost $4.50. (From City of Seattle report, "Household Hazardous Waste: Implementing a Permanent Collection Facility") This cost differential, the logistical difficulties of sponsoring Round -ups, the health, safety and environmental risks posed, the lack of convenience for users for the rational for not recommending Round -ups in the Final Plan. 34. The cost to dispose one tone of SQG waste is $681.59; a ton of HHW costs $1050 to dispose. 35. The Final Plan proposes aggressive SQG waste reduction and collection program components. 36. The plan focuses its detail on the initial 5 years. A plan update is scheduled in the fifth year of the plan. It will likely schedule the next plan update. Each year of the plan has a budget for program evaluation. This information could be used to modify plan implementation through the annual program budgeting process. 37. These spreadsheets have been revised. 38. The referenced collection sites are funded in 1989 and 1990 budgets. 39. Operating costs for mobile facilities includes handling and disposal. �allc' �ll�ll��csll A`�c3Clf 1p IVa�hlnKl.u� N..nprnlll l �xp..lal6.n 60 1-h., (.rrrn B"Jd.n ; 1VA `81111 • 206'622 6b95 Mr. Gregory M. Bush Metro Environmental MS -9 821 Second Avenue Seattle, WA 98104 Dear Mr. Bush: Planning Division March 26, 1989 I am writing on behalf of the 4,500 members of the Seattle Audubon Society to comment on the Draft Local Hazardous Waste Management Plan for Seattle -King County (and Draft EIS on the Plan). lie appreciate having this opportunity to offer our perspective. We are pleased with the quality of work that has obviously gone into preparing this document, and we commend the involved governments and agencies for working together in a regional spirit. Although regional coordination undoubtedly can prove challenging at times, it is well worth it to work together to promote efficiency and consistency in the management of the local hazardous waste stream. We urge you to continue with this regional approach as you move into implementation of the plan. Our specific comments are as follows. 1. The Seattle Audubon Societ recommends selection of the maximum diversion alternative (Alternative 1) which sets a goal o diverting 100 percent of household hazardous waste (HHW) and small quantity generator (SQG) waste from the municipal solid 1 waste stream, wastewater, and the environment in as short a period as possible (10-15 years). We recognize that this is costly in the short-term, but believe the costs are well worth it, and that it will prove the cheapest approach in the long -run. • Although local hazardous wastes constitute a relatively small volume of the municipal waste stream, even small amounts of these wastes can create significant environmental and health problems when mismanaged. it makes sound environmental sense to adopt a goal of diverting all of these wastes from mismanagement within the shortest possible timeframe. Putting a strong effort into waste reduction and recycling now will help to prevent costly contami- u.ltion problems in the future. • The maximum program also makes long-term economic sense when one considers the relatively low costs of diverting the wastes through waste reduction, versus the potential cleanup costs of wastes that are not channeled into proper management. State, local, and County governments around the nation are paying millions of dollars to clean up Superfund sites including solid waste landfills which have been contaminated in large part by unregulated HHW and SQG wastes. Unless current practices are changed, King County and the City of Seattle face a likely prospect of having to pay in the future for improperly disposing of today's hazardous wastes. Likewise, Metro may well be held financially accountable at some future point for discharges of toxicants into Puget Sound. As long as hazardous wastes are comingled with solid wastes and wastewaters, the involved utilities can anticipate an array of expenses caused by equipment failure, disruption of operations, and worker injuries. These current and future costs can be avoided by working aggressively to reduce hazardous wastes and remove them from the local waste stream, as proposed under the maximum diversion alternative. It is important to note that the maximum diversion alternative is the most efficient of the four alternatives, resulting in the lowest cost per ton of wastes diverted. • Finally, the maximum program also makes sound administrative sense by reducing liability and increasing certainty. - By reducing the volume of wastes produced in the first place, and by ensuring the environmentally sound management of the local hazardous waste stream, the involved governments can minimize their exposure to liability problems stemming from potentia contaminat on incidents. These liability risks are not insignificant, and they can be costly. In contrast, opting for less than the maximum alternative leaves the agencies open to liability problems. (We recognize that undertaking a local hazardous waste management program creates some liability problems as well, but believe that the liability exposure is greater where a known source of contamination is not being diverted to proper management.) State law requires local governments to adopt a goal of 100 ercent diversion. Opting for either the maximum or phased alternatives would a consistent with this, although the maximum diversion goal would achieve it more quickly. In addition the maximum diversion alternative would reduce uncertainty about the future acceptability of the region's solid wastes which may be landfilled out of region or out of state. (It is quite possible that receiving landfills will require the diversion of all hazardous wastes from any waste stream they handle to reduce their own risks of contamination. This requirement could be imposed in the foreseeable future -- perhaps sooner than the timeframe for achieving even the maximum diversion alternative.) Adopting the maximum diversion alternative would mean moving as quickly as possible in achieving these goals, and thus would contribute more certainty about the prospects of environmentally sound --and legally acceptable --waste management. Ip contrast, opting for less than a 100 percent goal leads to un- certain consequences. By selecting the maximum diversion alternative, the involved M = = = = = = = = M M M M r r M M M M M M M r M M M M M M M agencies and governments can cast a vote simultaneously for environ- mental, economic, legal, and administrative prudence. 2. In our view, the higher level of funding required for the 2 maximum diversion alternative is well worth the cost. Our basic reasons for supporting the maximum alternative are discussed above. We believe it is incumbent on the involved agencies to ensure that HHW and SQG wastes are diverted from improper manage - merit as quickly and effectively as possible, and that a strong emphasis is placed on waste reduction. We find the phased alternative (Alternative 2) to be inadequate in 1) its emphasis on waste reduction, 2) its emphasis on SQG wastes, and 3) its compliance component. The phased alternative would allow significant volumes of hazardous waste to remain improperly managed for an unacceptably long period of time. The maximum diversion alternative is the only alternative described that we believe has a good chance at significantly altering current consumer decisions and current waste management practices. We have some questions about whether even the maximum diversion alternative moves quickly enough and provides sufficiently convenient collection programs, but believe it would be a credible effort in the right direction. In selecting among alternatives it is not just a matter of the volumes of waste that will be diverted and the rate at which they will be diverted; it is also a matter of the intensity of effort and resources devoted to the program components. We find the maximum diversion alternative to be the only one with enough resources devoted to waste reduction and SQG wastes to be effective. 3. We want to emphasize the importance of waste reduction and the importance of education programs in achieving it. 3 A strong emphasis on waste reduction is critical to the success of a responsible local hazardous waste management program. A concerted, long-term program to promote waste reduction is the only way to significantly shift people's behavior with regard to toxics and other hazardous materials. Not only can a strong waste reduction program promote signficant changes in people's behavior in the home, but it can have a spill-over effect into the way people do business in society at large. As well as being the most environmentally sound approach to hazardous waste management (and being the State's top management priority), waste reduction clearly is the most cost-effective waste management technique. As noted in the draft plan, it costs $200 per ton of hazardous waste diverted through waste reduction, versus $1,300 per ton of hazardous waste diverted through collection. Education programs are of critical importance to the success of both the HHW and the SQG waste programs. Only with adequate outreach can people be convinced to change their habits. It is important to ensure that this program component is adequately funded, because the success of the program in changing behavior hinges on it. It should be noted that the educational programs can be expected to have several paybacks. Through an aggressive outreach program the public at large will become more attuned to the proper management of hazardous wastes --and more aware of the extent to which most of us use hazardous products in our home. Hopefully this will prompt people to begin to reduce the quantity of hazardous products they use, as well as ensuring the proper management of the wastes they do create. This should significantly reduce the local hazardous waste problem. It also could result in a decrease in the non -point source pollution of Puget Sound, which is attributed at least in part to the fertilizers and garden chemicals people use. We find the maximum diversion alternative is the only one that places adequate emphasis on waste reduction and education. 4 4. We su ort the combined a roach of ermanent dro -off facilities and mo ile units for co ection of HHW as ro osed under the maximum alternative, provide' de this would be supplemented by pickups or the housebound and curbside collection of batteries, waste oils, and other targeted. wastes. We do have some question about whether the number and type of facilities proposed under even the maximum alternative will be convenient enough to encourage proadspread participation in bringing HHW to the collection points. For this reason we would suggest using the early years of this system as a test period to evaluate whether the system is convenient enough. Also, we feel that this set of facilities must be supplemented by the curbside pickup programs described under the maximum alternative. We seriously doubt that a less aggressive approach will be effective in removing significant quantities of HHW from the waste stream. 5. We are pleased to see that the plan focuses on both HHW and_ 5 SQG, although only under the maximum diversion alternative To—we feel both waste streams are adequately dealt with. It will be important to keep this balanced approach when it comes down to funding decisions. Ideally we would like to see every business paying its own way for hazardous waste management. We recognize, however, that many small businesses are marginal, and that the cost of proper hazardous waste disposal is high. Wefeel comfortable supporting limited public subsidy of SQG wastes, simply because so many of these businesses are marginal and we believe it is very important to ensure that the wastes are adequately managed. We could support a subsidy of,say,25 percent of collection costs and provision of mobile and satellite disposal facilities as proposed under the maximum diversion alternative, provided that businesses using the subsidized facilities agree to ave a waste audit/waste management consultation and to follow through on recommended waste reduction measures. We have a few thoughts on financing the program. 6 We recommend an approach that supplements state monies with a reliable source of funds dedicated to hazardous waste management. Several of the funding avenues described in the plan would provide this. Our first preference is to raise local revenue through a local add-on tax levied at the point of purchase of hazardous roducts. This is the most equitable approach because the cost o proper hazardous waste management is being footed by those who benefit from using the hazardous material. Also a tax at the point of purchase could effectively prod consumers to change their behavior and switch to a non -hazardous product where substitutes exist. We strongly recommend exploring the possibility of this type of funding. Even if this were not to prove politically viable in the near future, we would recommend pursuing 1t, perhaps in con- junction with others needing to fund county/local hazardous waste planning efforts. If local governments were to jointly voice a desire for this type of funding to the State legislature, the chances -of approval would be greatly increased. In the absence of a local add-on tax, we have no strong feeling about the most appropriate funding mechanism. Conceptually it makes sense to charge homeowners when they dispose of HHW at a City or County facility (since they benefited from the product), but we have some concern that this may prove counter-productive. People already need to demonstrate a certain degree of commitment to proper waste management to be willing to drive their wastes to the HHW drop-off site. Given the transportation barrier, we question whether it is wise to create an additional disincentive to proper management of 11HW by requiring people to pay for it. We recommend exploring what types of incentives could he built into the funding system to encourage people to properly dispose of their wastes. 7 7. We strongly recommend a continued regional approach as this plan moves into the implementation phase. Given the involved agencies' intertwined roles in hazardous waste management, and given the benefits of a regionally coordinated system (efficiency and consistency), we think this plan should be regionally administered. This should be done through some formal mechanism, such as designa- tion of a lead agency or through a formalized interagency committee, similar to the one that developed this plan. It is our impression that the regional committee approach was found to be quite workable and largely satisfactory. Given this apparent success we would tend to favor the inteagency coordinating committee option. This approach has the added benefit of ensuring that all of the involved agencies feel responsible for the success of the program as a whole. 8. zLL. Please don't wait for the State to address the SQG problem. Clearly it is appropriate for the state government to play a significant role in providing technical assistance and other support programs for SQ generators. It also is appropriate to have outreach and assistance pruvided at the local level. Ideally the state and local governments would have complimentary roles in an integrated program. While the Seattle -King County program can and should attempt to prod the state to deliver some meaningful assistance in this area, we do not recommend waiting for the state to launch a comprehensive SQG program. The local program should move forward with as comprehensive an effort as possible. It can always be adapted if and when the state is able to assist. We hope that you find these comments helpful. If you have any questions, please feel free to contact me at 782-5004. Sincerely, .�3Tc+nrv,-ft Liz Tennant Toxics Subcommittee Seattle Audubon Society M M M M M M M M r M M M M M M M M M ars WVA RESPONSE TO LETTER FROM SEATTLE AUDUBON SOCIETY w 1., 2. and 3. Comments noted. See response to The Mountaineers, paragraphs 1 and 2. 4. The plan proposes a HHW collection component with permanent and mobile collection facilities. Service to the homebound is envisioned to be provided by existing volunteer service programs. The plan proposes demonstration projects to determine alternative methods of collecting certain targeted wastes. In some cases, curbside collection will considered. Prior to implementation, a variety of collection options will be evaluated, including curbside and drop -boxes. r The final plan includes a strong evaluation component during the first five years of implementation. Program evaluation will be used to improve the effectiveness of the programs, and to guide the development of new ones. 5. See response to City of Bellevue, item 6. 6. See response to City of Bellevue, items 7 and 8. 7. See Section 3, Plan Description, for the outline of the regional, interagency implementation strategy. M M F Washington Toxics Coalition Alar:h2o 1vw Grr Qury M Bush Manager Metro Fnvironmental Planning Division M S 92 `1215econd Avenue Seattle WA 981u4 RF Comments on Draft Local Hazardous Waste Management Plan Dear Mr Bush The Draft Plan and I nvironmental Impact Statement is an excellent piece of work It is thoroughly researched well organized and clearly written The authors are to he ci.mmended for producing an extremely useful document which outlines the problem and provides a range of alternative solutions whose impacts both environmental and ect numic are analyzed in great detail This document will be a most valuable planning tool We are pleased to see that the cooperative efforts of so many individuals and agencies have yielded work of such high quality, and we hope that this joint process will result in adoption and implementation of a comprehensive and balanced hazardous waste management plan The Plan Alternatives Thu only alternatives worthy of serious consideration for adoption are the Maximum Diversion Alternative (Max) and the Phased Implementation Alternative (Phased) It is clear from the graphs on pages 12-22 that only these alternatives achieve significant diversion of hazardous waste from the municipal (i a improper) disposal system The Status Quo Alternative would allow a serious situation to get worse at such a rapid rate that we could never hope to gain confrol of it While the Status Quo is not a realistic course of action its inclusion in the Plan serves as a useful baseline against which to measure the other alternatives The Fifty Percent Alternative while achieving 50 diversion in 20 years has no specific time limit for achieving 100: diversion Looking at the graphs on pages 19 and 20, it is clear from the slow rate of convergence that" I ilii . diversion is a lung way off if indeed it occurs at all We do not feel that a goal as important as 11111: diversion of hazardous waste should be assigned such a vague and distant Lime horizon We are doing the planning now, so we should take this opportunity to phase out improper disposal of dangerous wastes We are lett then with the Max and Phased Alternatives Were money no object. the 1 hoice of the Max Alternative would he clear The issue is justification of the added cost of hlax diversion We believe the added initial costs are well invested Both the Max and Phased Alternatives achieve the same diversion rate in 20 years but over those 2n } ears the Max Alternative diverts I I' nn0 tons 148: ) more hazardous waste than the Phased Alternative at an added dist of 28":, a much more economical diversion rate 2 There are two additional cuss savings gained by choosing the Max Alternative We would like to see these savings estimated in the Final Plan The first is the avoided disposal cost f the iddui, nal hazardous waste which is reduced or recycled under this plan These a� ings would he realised immediately The second avoided cost is the eventual 3 envu-unmental damage land required cleanup expenses) resulting from the unproper disposal nl the uicremental 117 (Pull tons of hazardous waste in the municipal landfill 4516 University Way N.B. Seattle, WA 98105, (206)632-1545 " IL IL__ � L R .. Lam..- C." M. and sewer system Prevention is always cheaper than cleanup We can be expected to have to pay for the consequences of improper disposal at some point, and migration of the toxics combined with monetary inflation will conspire to raise cleanup costs Education versus Collection While we strongly favor the Max Alternative, we consider the Phased Alternative to he a reasonable second choice In addition to its 20 year deadline for 100% diversion, the Phased Alternative has a strong education component We do not favor cutting education in favor of collection Education represents prevention—collection represents recycling and disposal Thus education is necessary to achieve the preferred diversion method For many hazardous substances the best available disposal options are less than ideal. From an environmental as well as economic point of view, waste reduction is the management practice of choice In order to maximize waste reduction it is necessary to foster a new awareness—indeed a new ethic—among both individuals and businesses The key to building this awareness is education. Citizens must be told the importance of avoiding unnecessary toxics, and they must be given specific. accurate, and useful information on available safe alternative products and strategies The Washington Toxics Coalition is actively engaged in collecting information on alternatives to household toxics, with a special emphasis on pesticides With regard to pesticides in particular, a simple substitution of one product for another is usually not possible The education must be more in-depth, taking account of life - cycles, timing, multiple control methods, and monitoring Overly -simplified educational materials can result in failure of alternatives methods. Frustrated by such failures. citizens can be expected to abandon their commitment to environmentally preferred products and return to purchasing toxics with renewed vigor We urge that implementation of the Plan include ample support for high-quality educational materials and services With regard to collection, the mobile vans seem a good way to achieve cost-effective collection services Household Hazardous Waste versus Small Quantity Generators Since SQGs produce more hazardous waste than households do, it may be tempting to cut funding for the HHW component of the Plan in order to save money We urge that a balanced approach be maintained It is true that HHW is more expensive to divert than SQG waste -1111W involves more individuals and more different chemicals Households are the major source of a number of components in the hazardous waste stream But more importantly, in addressing the problem of HHW we are targeting the bulk of the population This is the group that must be reached if we ever hope to achieve a long- term solution to the hazardous waste problem Educational efforts and programs aimed at HHW will also affect SQGs through pressure exerted by citizens who work in and patronize small businesses. Funding the Plan The Maximum Diversion Alternative will be expensive to implement It is important that it he funded in ways which are equitable. which provide incentives for the preferred management priorities, and which seek to encourage an economy based on the true costs of producing and using hazardous materials In this regard we favor N ` I funding based n taxing the sales of hazardous products and we disfavor fees fi-r disposal of HHW Fees for disposal of SQG waste are acceptable In the Plan it is stated that hazardous substance taxes are the most equitable funding mechanism and the one endorsed by the citizensof Washington through Initiative 97 These taxes tend to restore the true costs of using hazardous materials and provide a disincentive for their purchase by collecting cleanup costs in advance The projected income from the State 1-97 tax and from county add-on taxes are shown to be small in relation to the total cost of the Max Alternative If this is the case, we suggest that the tax rates are too low If the citizens of Washington are going to pay for a safe environment and if the hazardous substance tax is the fairest way to do it then the rates will have to be set high enough to do the job Why not add on a 5% tax or a 10% tax, or even a 25» tax if that is what is required? Hazardous substance taxes should be comparable to taxes on gasoline, liquor and cigarettes Fees for disposal of HHW are a disincentive to proper disposal In fact if these fees were set at the true cost of disposal. most households could not afford to use the services at all Since nominal fees lin the $5 range contribute almost nothing to the funding base, we think they could be dropped Disposal must be made easy It is purchase that should be discouraged With regard to businesses, user fees for disposal make more sense Regulations and enforcement can be designed to prevent significant illegal dumping, and disposal fees can be an incentive to develop new processes and techniques utilizing less toxic materials Implementation We think that a cooperative approach to implementation of the Plan is to be preferred because it avoids duplication of efforts, maximizes coordination between governments. and ensures uniformity of services We can see some advantages to both the committee and the lead agency organizational structures Our enthusiasm for a lead agency 5 structure would depend upon which agency was chosen. One positive argument for the committee structure is provided by the Plan itself If this document is indicative of the type of cooperation to be expected from the committee, we think that structure may well be the way to go Conclusion We welcome the opportunity to comment on the Draft Plan We look forward to seeing the Final Plan when it is released and will be pleased to comment on it as well Slpee Philip ukey �t (louse told Toxic . rdinator 5-50 .W RESPONSE TO LETTER FROM WASHINGTON TOXICS COALITION 1. Comments noted. See response to The Mountaineers, paragraph 1. 2. An estimate of avoided disposal costs attributable to .� reduction and recycling efforts can roughly be equivalent to the following. HHW: 159,410 tons X $682 (disposal cost/ton) _ $108 million SQG: 109,534 tons X $1300 (disposal cost/ton)= $104 million 3. Section 4, Affected Environment, discusses costs associated with municipal landfill clean-up costs that are, in part, attributed to local hazardous waste disposal. 4. Section 3, Plan Description, describes the proposed funding for the plan. 5. Section 3 of the plan describes the regional inter- agency plan implementation strategy. I 1 1 i 1 i 1 1 1 i CWQAC30 Years of Partnership (. ihicni Waler Quality Adviwry Committee appo rated by the Metro (ounr it to provide citizen advice on water quality. March 24, 1989 TO: Greg Bush, Manager Metro Environmental Planning Division FROM: Nancy Faegenburg, Chair CWQAC Local Hazardous haste Task Force SUBJECT: CWQAC COMMENTS ON THE DRAFT LOCAL HAZARDOUS WASTE MANAGEMENT PLAN/EIS The Citizens' Water Quality Advisory Committee, appointed to advice the Metro Council and staff on regional water quality issues and programs, has set up a special task force to review and comment on the Local Hazardous Waste Management Plan now being developed by member agencies and small cities. Following are our comments on the draft plan: (1) Overall comments on the Plan/EIB: We believe that this plan is timely and very much needed. - The City of Seattle's success in its recycling efforts is an indication that citizens are ready to work on recycling efforts on a personal level. - The plan presents a wide variety of elements that can be combined into a viable program to address the hazardous waste problem. - The final plan must ensure the committment of all jurisdictions to successful plan implementation. - The final plan should emphasize reduction, alternative products and prevention. 2 (2) Alternatives: Members of the task force recommend implementation of the maximum diversion alternative - The hazardous waste problem needs to be addressed head-on; this can be done most effectively under the maximum diversion plan. - This appears to be the best way to reach small businesses. V"' METRO dir Mum. ipality ul Mctngxditan Seattle, 821 ,e,ond Ave., M.S. 95, Seattle, VVA q8104-151)8 a 684-1138 1 f f f I i 1 1 I Comments on LHW Management Draft Plan/EIS CWQAC Task Force March 24, 1989 Page 2 - While the maximum divsersion plan costs more, it reduces waste more quickly, thus removing or keeping it out of the environment. - The more waste diverted now means less waste to clean up later on. - Maximum diversion will reach goals faster and appears to be the most cost effective. - Monitoring and evaluation as the plan is implemented can modify plan elements later if the initial maximum efforts are successful. 3 (3) Program Elements: The task force would like to see the followingolan elements highlighted: - Incentive programs encouraging research into new products (Appendix, page 9). - Outreach programs to small businesses, particularly those offering loans or grants for use of alternative products and field testing of such products. Program elements should emphasize reduction. - Research for less hazardous products - Improved manufacturing processes (waste exchange or reuse). Education/Collection plan elements Education efforts will be most effective if disposal/ collection of hazardous waste is convenient. Connect education efforts to specific collection events. - Curbside pickup may have been too readily dismissed in the plan. Possible options include product -oriented (targeted) recycling. (Costs for curbside pickup should be included so that people will understand the costs and impact involved.) - The plan should emphasize convenience. As stated the plan appears to encourage accumulation of hazardous materials in homes. Instead, the plan should encourage continuous disposal or elimination of these materials. - could have a regular schedule of mobile units (e.g. four times a year) in neighborhoods for collection of hazardous waste. One month may be too long a time to be in one location. Comments on I.HW Management Draft Plan/EIS CWQAC Task Force March 24, 1989 Page 4 7 (7) Financing: The task force sees a combination of local toxics control account funds (Initiative 97), solid waste and sewerage utilities and some kind of municipal assessment as the best way to share costs according to how waste is generated. Task force members feel that the plan should place some burden on the hazardous material user by increasing the cost. This way, those who do not purchase hazardous materials would benefit, and everyone who does use these products would share in the ultimate cost of disposal. Comments on IJ1W Management Draft Plan/EIS CWQAC Task Force March 24, 1989 Page 3 It is important that a special hotline phone number be included in any information going out to the public. People could use this number to find out not only where to dispose of hazardous materials but when the next mobile unit would be in their neighborhood. Encourage revisions to fire codes covering how hazardous materials are stored and sold. Orient con- sumers to new products and new behavior. 4 (4) Evaluation: Monitoring and evaluation of the plan need to be highlighted. - Who will evaluate? - what are evaluation criteria? - What data are to be collected? The local hazardous waste management plan needs to be made as flexible as possible. If, for example, collection of hazardous waste with mobile units was found to be more effective than collection at a permanent site, the option to adjust the program to include additional mobile units is necessary if this would made disposal/collection more effective. The task force recommends ongoing monitoring, with a major evaluation milestone in five years. 5 (5) implementation: We recommend a hazardous waste management committee as the bestway to implement the plan. A structure is already in place and works well, similar to the present informal system. This should assure communication among jurisdictions and keeping jurisdictions active in implementation. Local jurisdictions will have the flexibility to work out plans and program elements in their area with opportunity for approval and oversight from the group. 6 (6) Incentives: Need to use positive incentives. An example might be waiving the tipping fee if people bring waste to a transfer station. The plan should not have "negative" incentives. - The task force approves of having small businesses subsidized for a period of time. Positive incentives will be particularly important to help small businesses come into compliance. 1 1` 1 1 ! 1 ! ! 1 ! 1 ! 1 ! 1 1 5-53 RESPONSE TO METRO CITIZENS WATER QUALITY ADVISORY COMMITTEE 1. (1) Comments noted. The final plan emphasizes waste reduction, alternative products and prevention in conformance with the State waste management priorities. Section 3, Plan Description, describes the programs proposed for HHW reduction and education, waste reduction and technical assistance programs for businesses. Section 3 also identifies the local jurisdiction adoption process and the implementation strategy for the plan. 2. (2) The Final Plan is a hybrid of the Maximum Diversion and Phased Implementation alternatives presented in the Draft Plan/EIS. Programs are designed to divert the maximum amount of HHW feasible within a 10 to 15 year timeframe, and 15 to 20 years for SQG waste. The plan proposes an evaluation component which can identify appropriate modifications to the implemented programs as well as identify new programs for implementation. 3. (3) Waste reduction is a major emphasis of the plan. Programs include research, outreach and consultation to improve manufacturing and waste handling procedures, and waste exchange for business, as well as a comprehensive education program for households. The plan encourages new technologies and research through the program element "Promotion of SQG Waste Reduction, Recycling and Treatment". The plan proposes a network of mobile and permanent collection facilities for HHW. The objective is to provide accessible collection options for King County residents. Education efforts will be tied to collection services as well as conducted independently. The plan does not intend to encourage accumulation of materials in the home. A primary objective is to reduce the generation of HHW by encouraging use of less hazardous products. Where this is not possible, convenient, accessible collection services will enable households to dispose of their HHW as needed on an on-going basis. Evaluation of the mobile facilities program will aid in determining the appropriate length of stay at each site. The Telephone Information Line (the Health Department Hazards Line) will provide both waste reduction and waste disposal information. The state is currently reviewing the Unified Fire Code article on hazardous materials storage. Where Fire Code issues relevant to the management of SQG wastes arise in the future, the proposed IRAC would address them. 5-54 - RESPONSE TO METRO CITIZENS WATER QUALITY ADVISORY COMMITTEE (cont.) Curbside pick-up of targeted wasted, specifically waste oil, is under consideration. Cost of curbside pick-up for all HHW is included in Appendix A. 4. (4) Section 3, Plan Description, for a description of the Evaluation Component. - 5. (5) Section 3 outlines the regional interagency implementation strategy. (6) Comments noted. (7) See Section 3 for description of the proposed financing machanism for the plan. Rt 3 Box 338-C Vashon. WA. 98070 March 26 1984 Gregory M. Bush, Manager SEPA Responsible Official Metro Environmental Planning Division 821 Second Avenue MS -92 Seattle, W A. 98104 Dear Mr. Bush: The Local Hazardous Waste Management Plan for Seattle -King County has been reviewed from the standpoint of the Vashon Island cititzens' Groundwater Management Advisory Committee. Living on an island designated as a critical water supply area and with no current on -island means for disposing of hazardous waste, we are certainly happy to see this Plan. We submit the following comments: 1 • The mobile collection units would be an important asset for protecting Vashon Island's groundwater. We sure hope one will serve us. • The mobile collection units should be designed to meet any State Ferries requirements for transporting hazardous materials. Currently 2 gasoline and other such materials come the island on special ferry runs (no other passengers allowed). The schedule for the mobile station should be coordinated with those ferry runs. 3 • We favor the maximum diversion alternative, with three mobile units phased in by 1994 and aimed at 100% diversion of HHW in 10 years. • We favor funding through use of Initiative 97 tax and/or local add on 4 taxes on hazardous substances. Fees assessed to those bringing in hazardous materials will only lead to more substances being improperly disposed of, and ending up in the groundwater • We applaud the emphasis on education in the plan. We would like to 5 see an education program aimed at people using septic systems, and especially at people buying homes with septic systems who have been accustomed to homes connected to sewers. iSeptic tanks are the primary means for disposal of household waste on the island. The island has only one small sewer system.1 6 • The Implementation option of using a formally recognized coordinating committee seems best. Thank you for considering our comments. a ir��ac/6" //77 /V1) ys. Frank Jackson Dan Chasan Vice Chairman Chairman Vashon Groundwater Advisory Committee 5-56 a RESPONSE TO LETTER FROM VASHON ISLAND GROUNDWATER MANAGEMENT ADVISORY COMMITTEE. 1. King County Solid Waste Department is currently. developing its first HHW mobile collection program. Vashon Island is one area targeted for initial service under this program. 2. The transporting of hazardous waste from the island will be in compliance with all Federal and State transportation regulations. 3. Comments noted. 4. See response to The Mountaineers, item 4. 5. Comments noted. 6. Section 3 outlines the regional interagency plan implementation strategy. r f t r r r 1 r 1 1 Gregory M. Bush, Manager Metro Environmental Planning Division H.S. 92 821 Second Avenue Seattle, WA 98104-1598 re; Local Hazardous Waste Management Plan Dear Mr. Bush: I am writing to respond to the Local Hazardous Waste Management Plan proposed alternatives public information document. I am concerned about the proper disposal of hazardous waste. I encourage adoption of the maximum diversion alternative. I am not a small business owner, nor part of an environmental group. However, I believe this issue to be very important. It is my hope that Seattle can adopt a conscientious plan, and perhaps set the stage for other communities throughout the United States. I believe hazardous wastes are directly connected to the rise in cancer and other tragic illnesses that so many of us have had to face. While the maximum alternative may appear expensive, if we begin to figure in the human cost, as well as dollar cost spent in dealing with the repercussions of improperly handled toxic waste, then the maximum alternative cost begins to look less and less expensive, and more reasonable. I have a Clinical Rehabilitative Services Credential, a Master's Degree in Special Education, and I have worked in rehabilitation for several years. I encourage and support all of us taking up the challenge of making and keeping our city clean and liveable. Please feel free to contact me if any further information or discussion is desired. In support of the maximum diversion alternative, Sincerely, SusAn F. Colton 1 f 1 1 1 i a 1 1 uregoii 'Nasin Svstonls. IIIC. "Waste Management Company March 6, 1989 Gregory Bush, Manager Metro Environmental Planning Division M.S. 92 821 Second Avenue Seattle, WA 98104-1598 I want to take the opportunity to compliment your agency for your publication "Local Hazardous Waste Management Plan". As the General Manager of Oregon Waste Systems, which is constructing the landfill in Gilliam County, south of Arlington, Oregon, I view your plan as a perfect compliment to our efforts toward greater pollution control. The ultimate solution is to segregate the wastes out of the municipal waste stream and dispose of the materials in the most appropriate manner. While this may add costs to the generators and producers of the hazardous material, it will cause those products and services to more accurately reflect their true costs. This will result in waste minimization, reduction, or substitutions at the point of manufacture or use. Again, congratulations on your work to date. I wish.you success in its adoption. OREGON WASTE SYSTEMS, INC. L.c.IL_ Richard A. Daniels Vice President & General Manager RAD:lm RESPONSE TO LETTER FROM SUSAN F. COLTON Comments noted. RESPONSE TO LETTER FROM OREGON WASTE SYSTEMS, INC. Comments noted. 5-58 J Mer thekiurke S*wttle Long-It�nge Planning Municipal Building, km. 200 S—ttla, WA 96104 Ha. Local Hazardous Waste Management Plan EIS - Written Comments To Whoa It May Concern, I have reviewed the referenced EIS in its entirety. I have general comments and recommendations followed by EIS specific comments. My experience es a regi stared chemical engineer, small business consultant on hezardoua waste iaau*• and personal environmental concerns (surface .star and septic systems) gives as direct experience on these issue&. The general comments are the following: 1 ",a pinr., like virtually all other regulatory EI5a, does not approach the problem from a prlority/coat/benefit method. If the plan did no, they would come up with the following priority: a. Small quantity generators - small businesses. b. Small quantity generators - large businesses. C. Household waste to surface disposal. d. Household waste to septic disposal. e. Household west& to solid waste disposal. f. Household went& to sanitary &ever disposal. -" The first two on the list constitute more than 90% (versus the plena escertion of 66x) of the hezardoua waste. It could be virtually eliminated in leas then 5 years for leas then the proposed costs. Items c and d era worthy of pursuit only where they directly cause an environmental concern. The lest two have virtually no cause for concern though they are worth addressing on e much lower resource priority than the plan proposes. 2. The plan's intent to tackle the problem at the source is the most cost effective approach. For example, taking care of the problem with secondary sewage treatment is 3 - 10 times more expensive par pound of waste. 3. The plan'& narratives ren why SQG► do not comply in excellert. I find that most of them very much want to comply but the system make& it very difficult for them. I strongly recommend a atepwlse, 2 logical, nlmple English booklet on what waste is covered, design*- tion&, paperwork, glossary, disposal logic diagrams, etc. 4. Tone down the politically nice "come and see what we have" type of educational programs and focus on functional materials that have a "ho. to" format. Forget the picture& and regulatory aspects and get down to getting the west* alienated or placed where it belongs. Tho amount of HHW is grossly over es[imatad because it is indirect- ly derived from erroneous date. The amount of Industrial waste 3 diechurgad to the sanitary newer predicted by Metro'& 1984 Toxicant Pretreatment Planning Study (TPPS) is way too low. 1 consult to many of the sampled companies. The current amount of toxic waste r .I ved by Metro in, on the average, about one third the 1984 1 1 I I I I I f I levwls. Therefore, the amount of waste mathmatiely attributed to household• Is .oy too high. In the absence of industrial dis- charges, the household contribution would not be measurable In Metro's plant liquid influent or sludge discharges. 6. SQG compliance could exceed 90x in leas than five years if a program similar to Metro'& Industrial Pretreatment Group were used. 4 Thu cost would be considerably leas than the 100% diversion plan. About 25x of the currant SQG& could become non -hazardous waste generators if the they gat the right information and pursue reasonable operating practices. 7. The 25% SQG subsidy is necessary but should be progressive. The 5 large ahaatmetsl shop should pay full share while the small radiator shop should have a 65% subsidy. The social policy burden Is considerablg different across, the size spectrum of SQGs. 8. Sources of funding not considered in the plan could be extension& of existing methods. For example, Metro's industrial waste dis- h charge aurcharga end selscclva city garbage bill surcharges are reasonable, have low implementation cost and they are equitable. 9. Do not administer the program by committee. Set up specific SQG 7 end HhHW orgenizetlona within County Health and Metro. That 1& where te project specific expertise is located. If a committee is needed, make it advisory to the pro3ect implementation committee. Be sura and include other agencies that have some of the Anne goals like the Puget Sound Water Quality Authority. 10. All TSD faciltles do not have the patience, training or incentjtive to handle the limited knowledge of the SOG. TSD& do not have an 8 incentive to properly deaignat& and handle mmell quantities of west&. However, the SOG has sufficient intelligence to be stepped through the process and stick with it. Consider a SQG targeted booklet as a benefit to both the SOG and the TSD facility. It would be a plain English, semi -technical manual. 11. There are several avenues of education, direct training or restric- tion that are not included in the plan. They era: a. Homeowner Associations in new and existing housing develop- ments that enforce septic system disposal/maintenance and surface water requirements. This could be required through the County building permit process - especially in 9enverironmentally sensitive watersheds. b. Mket a "Homeowner's Ecology Guide" that would cover septic system requirementa, solid waste management, surface water protection and many other household environmental concerns. c. Many aspect& of the plan dovetail with the Puget Sound Water Quality Authority. Septic ayst&m■ and other surface water management issues are notable examples. 12. Through the now business license system, small quantity generators 10 couId be required to have a screening audit prior to starting business. Specific comments on the plan are the following: 11 1. Pogo 1-4, SQG& are not "unregulated". See WAC 173-303-070(8). Paq. 2 -Ib is more appropriate. These two {.ages should be consistent. 2. Page 1-5, even with Industrial and residential growth, at should nc,t he out os aticly as su a•d that waste gana—tion will Increase. An analogous situation with industrial sewer pretreatment hes reduced toxicants over 65% in less than 4 years despite a large increae• ]n 1 A1 industry and population. Europeen experience with hazardous waste Indicates a drop in poundage but an Increase in concentration. It is a common fault of waste stream analysis to predict tonnage Increases by simple extrapolation. In the free market system, usually waste streams will shrink as the cost, hassle and/or regu- lations make disposal more difficult. 3. Page 2-9 does not properly reflect the current and reasonably expected success of curbside recycling. 4. Page 2-29, the detection of toxic substances in Metro's influent h.is droaticly changed since 1784. I don't believe a full organic scan has boon completed since then. The pre -1984 data is not reliable for today's projections. To do so is misleading the public on the impact of old Industrial contribution versus todays Industrial and household contribution. Toxic organics are probably no longer measurable. Metals are about 1/3 what they were in 1984. The table Indicates 307 tons per year of toxicants go to Metro. This Is more than three times the current rate. Indeed, more than 15% of the metals in Metro's current effluent naturally occurs In the domestic water supply. 5. Table 2-10 appears to be based on Metro's Toxicant Pretreatment Planning Study. That study erroneously concluded the difference 13 botwaen Metro'• lndustrlal monitoring date end th• aaweg• plant influent et o household contribution. A comparison of th• pre -1984 and current Metro plant influent data shows the results of the TPPS study are wrong. Further, a simple mass balance of household water consumption and heavy metal concentrations In the source materials indicate the metals would be below detection limits at the plant. 6. In 1984, toxic organics once attibutad to households, actually originated from industry. For example, butyl phthelatoa were 1 thought to orglnat• !row plasticizers in synthetic clothes. It actually was from dye penetrants used to inspect aluminum parts. Virtually all company& have eliminated this type of dye penetrant. The statement on page 2-40 on Metro detected organics 1s not valid because of much more strict pretreatment enforcement since 1984. 7. The statement on page 2-42 regarding eliminating the pollutant at the source Is very good and should be emphasized. 8. Forget the "come and see me- type of education. Devote the resour- ces to the "go out and help thew- type. The statements on page 2- 50, bottom of 51 and 54 should be emphasized - especially about a conciao, readable, stepwise booklet for SOGs. This is the area of greatest payback. 1 4 d. The statements regard Ing Metro sludge quality and cadmium levels is eoai ly fixed. Require tha few (leaa than 10) cadmium electroplet.- era to close loop that part of their plating operations. The ►oulrcC c,1 cadmium is antarely andustrial and it Is arrunsously stated that some comes from households. Metro could pay the company& to install cadmium removal systems plus 10 year• of operating coat& and still wake a huge profit for the public by Upgrading the marketability of the plant sludge. 10. Alot of the bureaucratic work should be contracted to private 15 firms. Especially those concerning specialty expertise such as on- site consulting, waste minimization/elimination methods, etc. This route would be more thorough and coat effective. 11. The budgets for plan components should allow flexibility over time. 1 For example, a shift of funds from educational materials to techni- cal assistance programs may be prudent as the total program gets going. A periodic feedback and review process should be set up to Implement this flexibility. 12. The impacts and mitigation section is honest. We can't quantify the impacts but they do exist. The key is to priortize, do it, measure the results, stop part of the program when certain levels are schlsved and intltiete a maintenance program. Do not start a bureacracy and let it run forever. 13. BOG collection at satellite facilities should be minimized. The 1 most hazardous and higher volume materials, should go straight to a TSD facility. The collection of waste in one spot from *lot of users is not consistent with current land use. Current land use is only one facility's volume at one alta. The impact is more algnl- flcent as the collected volume is increased. The Metro facilities currently take In hazardous conatltuenta but not at concentration& that doseignate them as hazardous. As a collection site, Metro would then be taking in materials that ecutelly are designated as hazardous_ Th1a la not consistent with the current Metro land use. I tek• iaau* with pogo 4-6. The operating details should be more complete. Will thea& collection mites be subject to Ecology faci- lity permits? This should be set prior to the final EIS. Make Sure the facility permitting decisions are consistent with Indus- trial application&. 1814. The •ffactivanass of these programs 1s not demonstrated by simply &toting that other municipalities have done the some thing or that a certain number of cells were received. What are the directly measurable results? 1915. It is not demonstrated that a 25% BOG subsidy a sufficient inducement for proper dipsosal. I hope these comments are useful. Thank you for the opportunity to submit thew. If you have any question&, planes give as a call at 868-7804. Sincerely, Gregory R. Allan, P.E. cc: Ray Carvoth, Metro Environmental Lab 5-61 RESPONSE TO LETTER FROM GREGORY ALLEN 1. The analysis during plan development showed SQGs producing approximately two-thirds of the local hazardous waste (that waste addressed by this plan), based on available solid waste and wastewater data. The Technical Planning Committee, representing solid waste and wastewater ki utilities, has not found data supporting your assertion that SQGs contribute more than 90% of these wastes. 2. Comments noted. A booklet, as you recommend, will be considered as a part of the SQG technical assistance program. On-site consultation and other technical assistance programs should provide the "how-to" emphasis you suggest. 3. The plan's estimates are based on the available data for both the solid and liquid waste streams. The majority of the hazardous waste is found in the solid waste stream. Recent waste sorts have consistently found a level of hazardous waste in solid waste similar to that used in the plan estimates and projections. Admittedly, the data are limited and difficult to extrapolate from. It is also difficult to compare between waste streams. As a result of the limits on the available data, a number of planning assumptions were made to move the plan forward and develop management solutions. During plan implementation, the program evaluation component will collect new data upon which program and plan revisions will be based. The waste diversion estimates used in the plan are based on the best professional judgment of SQG waste management staff. Appendix B documents the process used to generate reduction and disposal projections. 4. If the plan projections are realized in a shorter timeframe than identified in the plan, revisions to programs will be made as a result of the evaluation process. 5. The SQG subsidy program will be developed in the first years of plan implementation. The concept of a progressive subsidy to help the very small quantity generators is compatible with the current thinking for this program and will be explored. 6. See "Financing" in Section 3 of the plan for proposed plan funding 7. See Section 3 for the outline of the proposed regional interagency implementation strategy. r 5-G2 "` RESPONSE TO LETTER FROM GREGORY ALLEN (cont.) 8. Research based on interviews with generators and hazardous waste handlers shows that more accessible disposal services for SQGs are needed to increase participation in proper waste management practices. The SQG component proposes incentives to broaden the TSDs role in SQG waste management. These include establishing SQG mobile and auxiliary collection facilities. 9. Comments noted. The HHW education program will include a number of mechanisms to inform the public. Those described in the Final Plan/EIS are examples of educational efforts that could be implemented. The Puget Sound Water Quality Management Plan supports the implementation of plans to manage HHW. However, it leaves specifics of program development to local hazardous waste plans. Opportunities to coordinate education efforts will be utilized where possible. 10. Comment noted and will be considered in the implementation of the SQG audit program. 11. Correction made in Final Plan/EIS. 12. Assumptions were made based on future population growth and current solid waste projections to project future tonnage of local hazardous waste, in the absence of any programs to address them. As disposal costs escalate and recycling is subsidized, per capita generation will likely decrease. Similarly, as programs are put in place that do increase "cost, hassle and/or regulation", it is logical to assume that some impact on the generation of hazardous waste will occur. This is reflected in the projections for waste reduction resulting form plan implementation. The projections for solid waste generation over the next 20 years are part of the most current projections used by King County. They show total solid waste generation before recycling and waste reduction are subtracted because local hazardous waste data are based on percentage composition prior to major recycling efforts went into effect. For planning purposes, it is assumed that hazardous waste in the municipal solid waste stream will increase in percentage of composition due to the presence of the major recycling programs, if no programs are implemented to address hazardous waste. 13. Data from Metro's Toxicity Pretreatment Planning Study were used to represent wastewater conditions in the absence of more recent and complete data. While this data set is a few years old and does not reflect the latest trends, it remains the best source for generalizations about the 5-63 RESPONSE TO LETTER FROM GREGORY ALLEN (cont.) wastewater stream. These data represent an upper limit on hazardous waste in wastewater and are useful for general planning purposes. Heavy metal levels have decreased in recent years, as the Final Plan/EIS notes, due to various source controls applied in the water supply and sewerage systems. Organic analyses continue for the collection system and treatment plants. They show a variety of hazardous organic compounds in the wastewater. Even purely residential wastewater contains measurable amounts of organic priority pollutants and metals at levels well above background water supply. Metro's Toxicity Pretreatment Planning Study did not derive household contribution of toxicants by subtracting industrial monitoring data from treatment plant influent. The study sampled numerous locations in Metro's collection system over a two-year period and assembled data on industrial, commercial, residential, inflow and other sources. A model was then developed to incorporate all these data into a picture of influent source composition. The model showed, among other things, that the predicted industrial contribution was much larger than Metro's permitted industries contributed based on direct industrial monitoring. This finding led Metro's Industrial Waste Section to focus more attention on the non -permitted business dischargers, for the most part, SQGs. Treatment plant sampling continues to find numerous organic toxicants in the wastewater influent at all five Metro plants, including the small, predominantly residential ones. Metro analyses and those of EPA and other sources confirm that household wastewater does contain detectable, measurable quantities of heavy metals and organic compounds. Sources of individual chemicals tend to be multiple; they come from a variety of sources which can change over time (by day, week, month, season). TPPS analyses detected plasticizers (butyl phthalates) in residential wastewater samples as well as in commercial land use samples, industrial samples and landfill leachate samples. Monitoring in Metro's sewerage system continues to detect toxic organics, including butyl phthalates, and metals. 14. The attached table list some of the possible uses of cadmium. It suggests that an "easy fix" for cadmium sources is not available. In addition to those uses found on the table, cadmium can also be found in tires. 15. The plan proposes education, technical assistance and increased collection opportunities for SQGs. SQGs will be referred to the proper type of vendor for the services they M RESPONSE TO LETTER FROM GREGORY ALLEN (cont.) require. Consultants or equipment vendors offering these services will benefit from increased demand due to this strategy. 16. One intent of plan implementation is to be as flexible as possible. The evaluation component will provide feedback on the strengths and weakness of specific programs and allow for changes and modifications, as necessary. Annual budget and program review will occur based on results of experience and evaluation. A plan revision and update is scheduled for the fifth year of the plan. 17. Collection operations proposed in the plan will comply with all relevant local, state and federal requirements. 18. Note above discussion on evaluation component. 19. The proposed subsidy is only one program of the SQG component. No one program will accomplish the goals of the plan. However, the subsidy is considered to be a viable element of a successful plan. Excerpted from: Key Manhole 1987 Results Page 3 - 10 POSSIBLE INDUSTRIAL USES OF HEAVY METAL COMPOUNDS DETECTED IN KEY MANHOLE SAMPLING COMPOUND NAME POSSIBLE USES CADMIUM The primary use of cadmium is as a sacrificial metal, especially in airframes. Other uses include: in solder for aluminum; electroplating (primary use); electrodes for cadmium vapor lamps; photoelectric cells; Ni -Cd storage batteries; dentistry (in Mercury -Cadmium amalgums); Cadmium salts used medicinally for swine and poultry; porcelain and pottery (produces an iridescent effect); reagent for determination of sulfur; tellurium; selenium; photography; process engraving; lithography; dyeing and calico printing; paint (cadmium yellow); galvanoplasty; manufacture of special mirrors; lubricant; analysis of sulfides; manufacture of phosphores; manufacture of glass (yellow colored); nuclear reactor controls; nematocides; semiconductors; manufacture of silver alloys; rectifiers; plant fungicide; Arsenic tests (catalyst); color for soaps; color for textiles, paper, rubber; printing inks; fireworks; X-ray screens; scintillation counters; catalyst for organic reactions; is present in tobacco. C� 1 I t t 1 1 / 1 t 1 1 z /Yl�e &S� Ak.1tIM m�-�cveRslo� AUP,,j--6i jc,. SJ�Q ti� U(I6Q /7\?� ��Y1(�'\(ire 'p , sill I� MICHAEL P/EL 71:"S( J51H 51 SAMUAI-" WA 9BOe5 1 i 1 1 f 1 I 1 1 7 March 1989 Jack Brautigam 3043 NW 62nd Street Seattle, WA 98107 Gregory M. Bush Metro Environmental Planning Division MS 92 821 Second Avenue Seattle, WA 98104-1598 Dear Mr. Bush I have carefully studied the four proposed alternatives for managing hazardous wastes and feel the maximum diversion alternative offers our best hope for adequate protection of public health and the environment. With maximum emphasis on public education and prevention of hazardous waste contamination, the long term costs of cleanup and disposal can be minimized. We should also be thinking about incentives for responsible hazardous waste management (as for solid waste), with strong support for use of safe alternatives. Thankyou for the opportunity to comment. Sincerely, (Jack Brautigam 5-66 RESPONSE TO LETTER FROM MICHAEL PIEL Comment noted. RESPONSE TO LETTER FROM JACK ERAUTIGAM Comments noted. 1 15 March 1989 Mr. Gregory M. Bush, Manager Metro Environmental Planning Division M.S. 92 821 - 2nd Avenue Seattle, Washington 98104-1598 Dear Mr. Bush: This letter is written to express my opinion about the information presented in the "hazardous Waste Management Plan Public Information Document" circulated recently. I appreciate having this opportunity. From the circular, all the plans as presented sound like viable options (though the 'do nothing' alternative is like cutting our throats). So far, in the environmental clean up plans, the household and small quantity generators of waste have "fallen through the cracks", and they constitute quite a large collective portion of the whole. At this time, I support that option called the 'maximum diversion alternative'. I don't think many people realize at this time that what we have done over the years of neglect is deadly: the systematic poisoning of our air, water and earth is slowly (though now accelerating) killing off everything, not just humans, frequently in painful manners. Hazardous waste is exactly that: life-threatening to all living things, especially as it accumulates without attention. I do request, however, that you make clear, no matter which alternative you choose, what the proposed alternative's fiscal policy will be. I am assuming some kind of users' fee or tax will be levied. It is suggested that, if you charge a fee at the collection stations, you will chase away those who will say "I can throw it in the garbage for free; why should I take the time and pay money to properly handle this?" Any fees should be spread out over everyone, as all contribute to the problem. Thus, within your funding management I suggest that all households bear a pro -rated fair share based on the percentage of hazardous waste generated by households and divided by dwelling units or persons per house. Sewage usage or some other standard unit could also be used for pro -rating. Businesses should also bear their fair share on a similar pro -rated basis. I noticed that the alternative I like proposes "financial subsidies" for small quantity generators (is this another word for businesses?) to encourage compliance. Letter to Mr. Gregory Bush Page 2 of 2 Unfortunately, this means that homeowners and other taxpayers must bear more of the cost than businesses, causing what would be perceived as an unfair addition on top of already burdensome taxes and levies. I do not feel that I am responsible for the 2 choices any business has made regarding its hazardous waste because I would choose to handle it properly if I owned a business. Therefore, instead of subsidies, I would suggest having the program loan the clean up cost to the business, with a pay back over time (including interest). This seems more fair, and everyone contributes to better survival chances. I hope that these comments are helpful to you in your consideration of alternatives. sincerely, NO -1 M. E. Blau 5-68 RESPONSE TO LETTER FROM M.E. BLAU 1. Comments noted. The plan financing is described in Section 3. 2. Section 3 describes the proposed financing of the plan. The HHW component will be financed through fees levied on residential solid waste and wastewater. The SQG components will be funded by fees levied on commercial wastehaulers. This is to ensure that households are paying for managing HHW, and businesses are paying for SQG waste. R I I 1 Iff I 1 1 t PETER H. VOGEL cwn a.ai. aan POST OFFICE BOX I0e8 COUPEVILLE, WASHINGTON 56236 T-1 ... a: 120616 76 3626 March 13, 1989 uregory M. Bush, Manager Metro Environmental Planning Division d21 Second Avenue MS -92 Seattle, WA 98104 bear Mr. Bush: I have read the summary of the Local Hazardous Waste Manage- ment Plan for Seattle -King County and have the following comments. 1. As tar as one can tell from the summary there is no specific method for, or assurance of, meeting the collection 1 schedules in any of the first three alternatives. Public apathy could leave the facilities and equipment standing idle and the subsidies unused or, on the other hand, the budget for these items could be unequal to meeting the demand by a concerned citizenry. Regardless of which alternative is chosen, should there not be contingency plans for correcting or accommodating unexpected variations in progress? If compliance lags, which residences and businesses will be the first subjects of enforcement? Should not this be predetermined to prevent charges of unfalrnees and insufficient lead time? If compliance exceeds the collection schedule, who will provide the necessary additional equipment, facilities, and subsidies in advance of the financial schedule? _. I did not see any basis in the report for the 2 anticipated amounts of hazardous waste reduction, nor any mention of any actions that could be relied upon to effect such changes. How can households and small generators reduce their wastes? How can the reductions be monitored? Who determines an acceptable level of reduction? If not acceptable, how can further reductions Lie required and enforced? 3. With regard to the Phased Implementation Alternative, are there, in reality, small quantity generators who would find 3 twenty yearslead time necessary and fifteen years insufficient? Would not either fifteen or twenty years be viewed as an opportunity to postpone working on reducing and recycling techniques? 4. In the Fitty-Percent Diversion Alternative, who will be in the half that is complying? It it is optional, how will fifty percent be reached? Could not this alternative result in ill feelings and disenchantment for those attempting to comply and a uimrnution of their eftorts? t f r r f t t a IF It Vogel 2 4 5. The first alternative may be the best because of the Intensive program needed to break through public resistance. Even ten years is a long time to maintain such an effort. I sincerely hope that you can develop a plan that clearly states what all households and businesses must do, how compliance will be monitored, and what enforcement will consist of. Very truly yours, L __3.-,_�(" 1% Peter H. Vogel, P. cc: Martha Burke 5-70 RESPONSE TO LETTER FROM PETER H. VOGEL 1. The program evaluation component is designed to monitor and analyze the effectiveness of the various programs during the first five years of implementation. This information will be used to change, modify or add programs. Initially, this will be done through the annual program and budget process, and then through the plan update and revision in the fifth year. 2. Assumptions on hazardous waste reductions are found in Appendix B, pages B-3 to B-6. Section 3, Plan Description identifies specific programs for acheiving waste reduction, monitoring and enforcement. 3. The final plan proposes to accomplish the goal of diverting the maximum amount of local hazardous waste feasible in a timeframe of 10 to 15 years for HHW and 15 to 20 years for SQG waste. 4. Please not that the final plan is a hybrid of the maximum diversion alternative and the phased implementation alternative described in the Draft Plan/EIS. 1 I r t PRE 511 MR 6 1989 DUARTMRFIOFMUC � soup rustt oms+aY a SAP PC 0-------- ofc: Id.ner se -r Ficurw /Lao c. -'v- nkwfir 5-72 1 RESPONSE TO LETTER FROM KARIN STEVENS The goal of the plan is to significantly reduce the amount of hazardous waste being inappropriately disposed of by households and certain businesses. It is beyond the scope of this planning effort to implement a ban on the manufacture and distribution of hazardous materials. t 1 l Vt:—V ) , X W - p4 T T 41Y *7;zwror -r.Tpm '0 --VF '7"'n -Y i -r.-- V rrT S- W� D' �vv -� �-r �-�T �1 '! Y ' ��"al'�' -M-7t `�y Ar NP Y-Qrry "4 �f/ 4---- 5-74 RESPONSE TO LETTER FROM ROBERT L. CASALE 1. The Final Plan is a hybrid of the maximum diversion and the phased implementation alternatives presented in the Draft Plan/EIS. 2. Section 3, Plan Description, presents the financing of the plan implementation. 3. A regional, interagency implementation strategy is proposed for the plan. s D D 11 APPENDIX A PROGRAM ELEMENTS A-1 TABLE OF CONTENTS HOW THE PLAN WAS DEVELOPED ............................. A-2 PROGRAM ELEMENTS ........... .......................... A-7 Household Hazardous Waste Education ......................... A-7 Household Hazardous Waste Collection and Waste Handling .......... A-18 Small Quantity Generator Education and Technical Assistance ......... A-27 Small Quantity Generator Collection and Waste Handling ............ A-35 Compliance .............. .......................... A-39 Program Elements not Included in the Plan .......... ... ....... A-46 I:\UUM101ir1 PROGRAM ELEMENTS A-2 AN This Appendix contains detailed descriptions of each of the ar program elements in the Plan, beginning on Page A-7 It also describes the history of Plan development. HOW THE PLAN WAS DEVELOPED In July, 1987, the Department of Ecology issued Planning Guidelines for Local Hazardous Waste Plans. Each local government or combination of local governments is required to prepare a plan based on these guidelines. King County agencies have chosen to use a cooperative planning strategy. Five lead agencies are participating in the development of the King County Local Hazardous Waste Management Plan: King County Department of Public Works Solid Waste Division; City of Seattle Office for Long-range Planning and Solid Waste Utility; Seattle -King County Department of Public Health; and Metro's Water Pollution Control Department. Other supporting participants include the Suburban Cities Association and Metro's Environmental Planning Division. The senior managers and office directors of the five lead agencies signed a Memorandum of Understanding that designates the roles and responsibilities of each agency and established the Technical Planning Committee. The Technical - Planning Committee is charged with the responsibility of developing the plan. The Memorandum of Understanding also requires a Senior Management Committee to review and approve the work of the Technical Planning Committee (Figure , A-1). The Technical Planning Committee developed a goal statement no and set of objectives to meet Ecology's guidelines, as well as identified problems and needs. These guidelines require, at a minimum, the following issues to be addressed and programs so to be considered: • consideration of state hazardous waste management priorities; • ongoing information and education efforts for both the public and businesses that emphasize waste reduction; • local ordinances that address hazardous waste in the solid and liquid waste streams; • on-site audits of businesses that are likely to be SQGs, by targeted industry; Ni _P Elected Representatives Executive/ Todd Yerkes, Mayor/ City of Seattle Metro Metro Council King County Solid Waste Utility Office of Seattle City Pruitt -Davidson Water Quality Council Suburban Cities Council Committee Rod Hansen, Manager, Solid Waste Division, Department of Public Works Scott Blair, Henry Draper King County Solid Waste Division Richard Yukubousky, Director, Office for Long-range Planning, City of Seattle Martha Burke, City of Seattle, Office for Long-range Planning Senior Management Committee Diana Gale, Director, Solid Waste Utility, Engineering Department, City of Seattle Technical Planning Committee Board of Health John Lampe, Superintendent, Office of Water Quality, Metro Suburban Cities' Councils Chuck Kleeberg, Manager, Environmental Health Division, Seattle -King County Department of Public Health Chris Luboff, Dave Galvin, Todd Yerkes, Geoffrey Ethelston City of Seattle Metro Seattle -King County Cynthia Solid Waste Utility Office of Department of Pruitt -Davidson Water Quality Public Health Suburban Cities Association Figure A-1. ORGANIZATIONAL CHART FOR DEVELOPMENT OF THE LOCAL HAZARDOUS WASTE MANAGEMENT PLAN a W APPENDIX A PROGRAM ELEMENTS A-4 I • a system for collecting HHW or otherwise diverting HHW from improper disposal; • efforts that target selected wastes or waste sources; • a system for ultimate handling of the hazardous wastes collected (if not provided by the private sector); • monitoring, surveillance and enforcement programs; • assignment of lead responsibilities and time frames for implementation; and • a revision process and schedule for plan updates. Using the guidelines, Plan goal and objectives (Section 1), the Technical Planning Committee developed specific strategies for addressing the management of HHW and SQG wastes -- the components described in Section 3: HHW Education; HHW Collection; SQG Education and Technical Assistance; SQG Collection; Compliance; and Evaluation. The programs in each component are the building blocks of the Plan. These program elements were identified from potential programs and activities suggested by public comments and other research efforts. A variety of factors were investigated and described for each suggested program element: • what would the program do? • how would the program meet the state's waste management priorities? • what safety or environmental issues would the program solve or create? • how compatible would the program be with existing or proposed programs? • what would it cost? • are there any legal or logistical barriers to implementation? and • what experience exists locally or elsewhere to demonstrate program effectiveness? From the guidelines, goals and objectives listed above, evaluation criteria were developed to test the effectiveness of proposed program elements in meeting the Plan's goal and objectives (Table A-1). Only those elements which adequately met the criteria are incorporated. Each program element was compared, if necessary, with similar elements that would achieve the same result. When programs appeared to be redundant, the most effective program was chosen. g► so 71 Id as so _F, rii APPENDIX A PROGRAM ELEMENTS Table A-1. EVALUATION CRITERIA A-5 • Meets state and local legal requirements. • Diverts significant amounts of hazardous waste from municipal waste streams. • Promotes state management priorities in descending order: reduction, recycling, treatment, incinerations, solidification/stabilization, and landfill. • Is cost-effective compared to other elements that achieve the same result (on a cost per unit waste diverted basis). • Fosters public awareness. • Is responsive to the needs and processes of the targeted audiences (e.g., convenient, accessible, promotes involvement and participation). • Fosters generator responsibility (results in changes in user behavior). • Encourages private sector innovation in the development of solutions (stimulates entrepreneurial creativity). • Is compatible with solid and liquid waste systems' plans and operations (enables waste management facilities to continue meeting all standards and permit requirements; reduces liability to agencies). • Promotes worker and public safety. • Has synergistic potential (builds upon and complements existing programs and proposed program elements. • Is environmentally sensitive (no significant adverse impacts). • Is feasible (can be set up and will actually work). APPENDIX A PROGRAM ELEMENTS m M rr Eliminated Program Elements In addition to the Program Elements in the Plan, several program elements were investigated and eliminated from further consideration for a variety of reasons: HHW Home Audits. This labor intensive effort is not considered effective enough to justify its expense. An insufficient number of households would be reached in comparison with other methods of educating the public. HHW Waste Exchange. The small amounts of wastes that households donate rarely permit effective exchange. The lilot - ability concerns are great, as a person could unknowingly be exposed to mislabeled or contaminated products. "Over the fence" exchanges between neighbors could be encouraged via s the Hazards Free Neighborhood, the Telephone Information Line or other methods. HHW Door -to -Door or Curbside Pick un either by go appointment, at the curb during regular solid waste or recyclables pick up, or in a similar fashion by a separate contractor. Although any of these collection options offer the maximum public convenience, they are all prohibitively possibly promote illegal practices. Enforcement would be expensive; collection costs can be up to ten times higher than r other collection programs. Safety concerns are also unresolved; for example, wastes left unattended in the sun may explode; improperly packed wastes may spill or mix; and people and animals may be inadvertently exposed. waste. To date, the Round -ups in King County have relied on Elimination of SQG Exemptions to change existing state regulation to treat all SQGs as regulated generators. This would require state legislation and administration; it could not be done at the local level. It would also reduce flexibility and possibly promote illegal practices. Enforcement would be extremely costly. HHW "Round -ups" are not considered desirable due to the high collection cost per ton and the logistical problems with organizing enough events to collect a substantial amount of waste. To date, the Round -ups in King County have relied on hundreds of volunteers from local agencies, as well as the support of businesses and community groups. Relying on this mobilization to serve a relatively few households is becoming more and more difficult. 77 M OR HOUSEHOLD HAZARDOUS WASTE EDUCATION PUBLIC INFORMATION AND OUTREACH The public information and outreach program would provide information about proper disposal of HHW, recycling, waste reduction and other issues. The goal of this program is to bring about a long-term change in consumer behavior by educating the public to recycle, to dispose of wastes properly and to buy and use products that do not contain hazardous constituents. Program strategies and activities may include: • development and dissemination of printed materials, such as posters, fact sheets, flyers, brochures, booklets, utility bill inserts and bus placards; • development of durable traveling displays, slide shows and videos for presentations and workshops; • communication with reporters and producers, writing a newspaper column or series of feature articles, staging media events, production and distribution of PSAs or paid advertisements, regular appearances on radio or TV talk shows; and • special events. In addition, special projects would be undertaken to target specific audiences such as self - haulers or specific waste streams such as used motor oil. This program is divided into two main categories: a) General Promotion and Publicity and; b) Waste Reduction Promotion. .. Sample projects are listed below and described on the following pages. ■• GENERAL PROMOTION AND PUBLICITY • Hazards Free Neighborhood • Education at Municipal Solid Waste Facilities ••6 Storm Drain Stenciling • Garbage Can Stickers .. WASTE REDUCTION PROMOTION • Oil Recycling Education • Promotion of Oil Recycling Opportunities 0 Product Packaging Alternatives • Product Labeling • Promotion of Safer Products ,,.0 Citizen Waste Treatment Program W a* M A-7 M M r GENERAL PROMOTION AND PUBLICITY on HAZARDS FREE NEIGHBORHOOD A "Hazards Free Neighborhood" program would inform communities of the environmental and safety implications of improper handling and disposal of certain household products. The program would emphasize using safer product alternatives and waste reduction. By pooling community resources, the program would give individuals more HHW handling �+ options. The program aims to motivate individuals to reevaluate which products they buy and use, and to encourage behavior changes in this regard. Each participating member of the neighborhood would receive a sticker or decal to display. The logo indicates that the .r household has helped in keeping the neighborhood "hazards free". The formal parts of the program would be run by a coordinator who would organize ..� neighborhood volunteers. Volunteers would be responsible for the following: o distributing brochures and printed information; o coordinating waste recycling and disposal efforts; o coordinating an informal product sharing effort. .r Increased awareness could lead to informal waste exchange programs and other cooperative H1 -1W management efforts. For instance, citizens could pool resources and take their neighbors as well as their own recyclables to the recycling center. Products that are no longer needed by one individual may be usable by another; leftover paint or oven cleaner could be given to a neighbor to use. The only limit to potential activities is the creativity of the participants. POTENTIAL BARRIERS This program requires substantial commitment from individuals and would probably be most successful in communities that already have close ties. Other communities might not do so well at a coordinated effort. DEMONSTRATED EFFECTIVENESS Crimestoppers is an analogous program that was successful at reducing crime through a cooperative neighborhood watchdog effort. EDUCATION AT MUNICIPAL SOLID WASTE FACILITIES so This program would provide users of solid waste disposal facilities -- transfer stations, landfills and recycling centers -- with information about proper disposal of hazardous .N wastes. Users of these facilities, called "self -haulers," contribute a large proportion of hazardous wastes to the municipal waste stream. Signs and self -serve kiosks containing informative literature would be placed at solid waste disposal facilities. Facility staff would be trained to answer questions and provide information on correct methods of " hazardous waste disposal. Both householders and commercial waste generators use these facilities and, therefore, both would benefit from these efforts. A-8 A COSTS One kiosk $2000 Staff training (per site) 7000 Annual retraining 3300 LEGAL ISSUES If hazardous waste is turned away from the transfer stations without legal and convenient + disposal alternatives, illegal dumping could occur. W STORM DRAIN STENCILING Ecology currently sponsors a storm drain stenciling program. Interested volunteers use a .. stencil to apply the message: "DUMP NO WASTE. DRAINS TO STREAM" to the pavement next to storm drains. Environmentally benign paints are used. Under this program, staff would obtain permission from local street use agencies or private property .. owners to apply the stenciled message, recruit volunteers and organize stenciling events. DEMONSTRATED EFFECTIVENESS .. Ecology's stenciling program has proved to be a very popular one. GARBAGE CAN STICKERS A sticker would be affixed to all garbage cans and residential dumpsters stating that hazardous household chemicals should not be dumped in the trash. The sticker would refer readers to the Hazards Line (operated by the Health Department) for information on proper disposal. The stickers could be distributed by a) affixing them to cans and dumpsters prior to delivery to customers; b) mailing to customers to stick on the cans themselves; or c) sticking on during collection by garbage contractors or by specially -assigned personnel. ENVIRONMENTAL AND HEALTH ASSESSMENT If legal disposal options are not readily available, illegal dumping may result. t1 COST 50,000-125,000 stickers $15,000420,00 POTENTIAL BARRIERS Distribution of stickers presents some logistical difficulties. Costs of distribution, for example, mailing or staff costs may be too high in comparison with the program's usefulness. This program is compatible with agency -run collection contracts where garbage cans are supplied. Implementation would be more difficult where private contractors pick up trash or where customers purchase their own cans. 71 7 This program would be most effective if supported by regulatory bans on disposal of household hazardous waste in the solid waste stream. This would require political action and could be difficult to enforce. DEMONSTRATED EFFECTIVENESS M In early 1989, the City of Seattle distributed trash cans to all residents eligible for and interested in curbside pickup. These cans have either a sticker on the inside of the lid or an embossed message on the lid. The label indicates that citizens should call the Hazard ••► Line for disposal information. There has been an increase in the number of phone calls received at the Hazard Line, although many questions are regarding solid waste disposal. In the future, label information could be revised to alleviate this problem. ,rr The Environmental Health Division in San Diego, California has a "Curbside Enforcement/Education Program" that involves putting labels on residential garbage cans .. and dumpsters. The program is also developing a tag system to identify hazardous wastes that have been disposed in the trash. Haulers will place a tag on the trash can when hazardous wastes are found and informs the citizen of proper disposal options. mr A-10 M W M W M r WASTE REDUCTION PROMOTION OIL RECYCLING EDUCATION Public education concerning oil recycling is an important component of a successful oil recycling program and therefore, of a HHW management effort. Education would include: o public service announcements on radio, TV and in newspapers; o educational films and videos shown in schools, at fairs, home shows and other events; o development of pamphlets, flyers, coloring books and other educational materials for different age groups; o special information or programs at recycling centers; r- o bus placards and billboards. The only limits to promotional activities are funding and the imagination of program .. coordinators. ENVIRONMENTAL AND HEALTH ASSESSMENT Oil recycling diverts used oil from the liquid and solid waste streams, storm drains and disposal on the ground. Better management of oil will result in benefits to water quality, as well as conserving a non-renewable resource. P. DEMONSTRATED EFFECTIVENESS The Snohomish County Solid Waste Division has developed videos promoting the proper .. disposal and recycling of used motor oil. Ecology has developed pamphlets on recycling and disposal of used oil. PROMOTION OF OIL RECYCLING OPPORTUNITIES This program would increase recycling capacity for used oil, by: • encouraging more businesses to accept used motor oil. Candidate businesses include service stations, "speedy" oil change shops, automotive repair shops and/or retailers; • encouraging state enforcement of RCW 19.114 which requires retailers selling more than 100 gallons per year of oil to post signs listing nearby oil recycling depots; • providing lists of oil recyclers to the retailers; • promoting the sale of plastic combination drain pan/oil containers; • encouraging recycling centers to accept oil • promoting the collection of used oil at transfer stations. ENVIRONMENTAL AND HEALTH ASSESSMENT This program will provide more collection options for used motor oil. This will result in less oil entering the municipal waste streams and the environment. A-11 U ►MPATIBILITY WITH EXISTING PROGRAMS is program would be compatible with existing collection and education programs. ceased enforcement of RCW 19.114 would make recycling opportunities more visible to public. Solid and liquid waste facilities would benefit from used oil collection grams. GAL ISSUES contaminated with chlorinated solvents must be disposed of as a hazardous waste. PRODUCT PACKAGING ALTERNATIVES der this program, product packaging alternatives would be developed and promoted. ;cific activities would include: researching consumer behavior on product purchasing; exploring incentives for and working with manufacturers and retailers to encourage the marketing of products in smaller sizes (which would result in less left -over product and therefore less waste); exploring options such as selling concentrates to be mixed at home; and promoting these ideas and alternatives to the public. ., als for certain priority waste stream (e.g., paints) could be set, with sales figures, veys or waste characterization studies used to evaluate progress. ESTE MANAGEMENT PRIORITIES )motion of smaller -sized products would reinforce the top state waste management priority of reduction. Over time, purchasing behaviors would be altered. ENVIRONMENTAL AND HEALTH ASSESSMENT Promotion of smaller packages would result in less excess product, less exposures and less waste, thus positively affecting worker and public health and the environment. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS This program is compatible with existing programs. LEGAL ISSUES There are no legal issues. POTENTIAL BARRIERS Manufacturers and retailers may be reluctant to change current marketing and packaging practices, or to promote alternatives. Public may be unwilling to change purchasing .r� practices. DEMONSTRATED EFFECTIVENESS Almost all HHW programs in this country promote buying smaller amounts of hazardous products. None offer incentives or have worked directly with manufacturers or retailers on this issue. ij A-12 European consumers are much more willing to purchase concentrates and mix usable solutions at home, according to the Chemical Specialties Manufacturers Association. Why this is, and what it would take to change American behavior are not known. ! PRODUCT LABELING Under this program, consumers would be alerted to products that have special environ- mental and safety implications. Manufacturers would be encourage to convey a number of •• messages, via labels, including proper disposal methods and promotion of waste minimiza- tion. The labels could also flag recyclable products or those that contain hazardous materials. Less hazardous products could be awarded an "Environmentally Safer" label, ■. similar to the "Good Housekeeping Seal of Approval." Labels could be affixed to the products themselves or signs or stickers could be placed on a shelf near the product. r,. This program would target all consumers and provide necessary information for shoppers to select less hazardous products. Labeling at the point of sale makes information highly visible and accessible to consumers. ! WASTE MANAGEMENT PRIORITIES Product labeling would promote waste reduction by encouraging consumer selection of safer products and proper waste management behavior. ENVIRONMENTAL AND HEALTH ASSESSMENT This program would enhance worker and public health and protect the environment by reducing the amount of waste generated. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS This program is compatible with existing and proposed programs. Enforcement of product ' labeling and motor oil recycling information requirements could be combined. LEGAL ISSUES Labeling products would require state or federal legislation, as local ordinances are ineffective for products made out-of-state. Such requirements might be construed to conflict with the Commerce Clause of the U.S. Constitution which prohibits the enactment of laws that interfere with the free flow of goods in interstate commerce. Manufacturers may view marking their product libelous; therefore, liability may be an issue. Labeling on shelves can be mandated at the local level but would be more effective if mandated at the state level. POTENTIAL BARRIERS As the use of labels increases, their effectiveness diminishes. " Industry support may be difficult to obtain. Enforcement may be difficult, unless retailers support the project. A-13 M s DEMONSTRATED EFFECTIVENESS I Germany has a "Blue Angel" emblem program that identifies environmentally safer products. This emblem is displayed on over 450 products. .i Iowa's Groundwater Protection Bill of 1986 requires stickers to be placed on products that need special disposal. Signs are posted at the end of store aisles to explain the purpose of the sticker. Compliance, however, is poor. PROMOTION OF SAFER PRODUCTS Research would be conducted to evaluate products and compile lists of those that are less hazardous than others in various product categories. Once this information was compiled, it would be made available to the public. In addition, the development of safer alternative products where none are currently available would be encouraged. Targeted product types would include pesticides and cleaning products, though all hazardous product categories could be addressed. WASTE MANAGEMENT PRIORITIES This program would contribute to waste reduction, the top state waste management priority. ENVIRONMENTAL AND HEALTH ASSESSMENT 4 Promotion of safer products would directly and positively affect public health and the environment. I COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS This program would be compatible with existing programs. LEGAL ISSUES Trade secrets would hinder research into existing products. Public agency endorsement of one product over another could present legal difficulties. Selection criteria would have to be clear, rigorously followed and unimpeachable. An alternative approach would be to fund an independent party, such as a nonprofit , organization, to develop and publicize the information. POTENTIAL BARRIERS Other than the legal issues, there are no potential barriers. DEMONSTRATED EFFECTIVENESS The Washington Toxics Coalition "Home Safe Home" program included promotion of some name brand alternatives. Alternative, make -it -yourself recipes are available from a number of sources. A-14 r— M 0 CITIZEN WASTE TREATMENT Educational materials would be developed to instruct citizens on ways to handle and dispose of certain household hazardous wastes at home. This program encourages householders to recycle wastes where feasible, and to "treat" certain wastes so they become non -hazardous and may be disposed in an environmentally sensitive manner. Examples of "treatments" for specific wastes are listed below: 1. Paint solvents: Allow used paint solvents to sit until paint particles settle. Decant the solvent for reuse and dispose of the paint particles in the garbage. r 2. Latex paint: Allow small amounts of unwanted latex paint to dry in a well ventilated area and dispose of the solid paint in the garbage. 3. Drain cleaners and antifreeze: Flush down the drain with plenty of water. .� ENVIRONMENTAL AND HEALTH ASSESSMENT Information should stress safety and protecting against possible exposures. ,.. LEGAL ISSUES Liability if injury results when procedures are not followed correctly, for example, if solvent -based paints are allowed to dry rather than latex, and significant exposure to solvent fumes results. DEMONSTRATED EFFECTIVENESS Minnesota has produced fact sheets encouraging citizen involvement in waste reduction, including paint drying and solvent settling. In Missouri, information is provided to encourage volatilization of solvent -containing products in a "volatilization box". Missouri also publishes a list of products that might be considered hazardous but are acceptable in municipal landfills, allowing citizens to distinguish hazardous from non -hazardous wastes. HHW TELEPHONE INFORMATION LINE HHW Telephone Information Lines provide residents with the latest information on proper storage, handling and disposal of household hazardous waste. The telephone line will have a publicized toll-free number available to King County residents. The telephone service will provide publicity for HHW programs and events, in addition to waste management information. WASTE MANAGEMENT PRIORITIES Phone lines promote proper handling of hazardous wastes and can provide users with information emphasizing the State's higher waste management priorities. A-15 W ENVIRONMENTAL AND HEALTH ASSESSMENT The information provided by the phone line staff would include recommended procedures .f that minimize risk and promote public safety. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS .. The Seattle/King County Health Department operates the Hazard Line. Additional phone lines would be compatible with this program. Phone lines can promote HHW collection facilities and programs. COST Costs would be dependent on the number of trained staff answering the phone line. Costs .� for a 1 FTE program are: Year 1 Year 2 Staff (per FTE) $40,000 $60,000 Admin/supplies 10,000 15,000 LEGAL ISSUES tir Liability if injury or problems result due to incorrect or misinterpreted information. POTENTIAL BARRIERS None. DEMONSTRATED EFFECTIVENESS „N The Seattle -King County Health Department Hazard Line has averaged over 735 calls per month for January through July, 1988. Ecology's Hazardous Substance Information Line has responded to 550 calls/month in 1988. SCHOOLS PROGRAM A comprehensive schools program would teach children and adults about the health and environmental effects of hazardous products and about personal responsibility for proper hazardous waste management. Such a program would require: • Development and distribution of curricula, such as lessons on identifying hazardous products in the home for young children; safe use and disposal of hazardous waste in related high school classes such as art, woodshop and driver training; case study materials and standardized courses for use in two- and four-year colleges. Widespread distribution of materials would be encouraged. • Teacher training and workshops to prepare teachers to use curricula. • In -school programs, including traveling presentations on HHW alone or in conjunction with other environmental topics such as water quality, recycling, etc. New programs developed under the Plan would be coordinated with existing programs. A-16 W .r we WASTE MANAGEMENT PRIORITIES School programs contribute to waste reduction, the top waste management priority. ENVIRONMENTAL AND HEALTH ASSESSMENT .. People informed about HHW through the schools program, by their children or from their own attendance, will use and dispose of hazardous products properly, increasing safety in the home and decreasing the risks associated with these products in the waste stream. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS The proposed schools program will enhance existing school programs. Coordination may be possible through the State Office of Environmental Education. COST ,,. Year 1 Year 2 Staff 1.0 FTE $40,000 $40,000 Admin/supplies 20,000 20,000 Workshop presentations 40,000 40,000 Curricula development 70,000 65,000 Travel expenses 5,000 10,000 Teacher Training 0 40,000 In -school programs 0 40,000 LEGAL ISSUES There are no legal issues. POTENTIAL BARRIERS The procedure for instituting a new curriculum requirement in grade schools is long and difficult, and would probably require state action. However, school boards can be encouraged to offer these programs, for example, by including discussion of HHW in the r` existing hazardous materials requirements for science classes. e King County has 20 school districts that would need to be approached separately. Obtaining credit for teacher certification and continuing education may be difficult. DEMONSTRATED EFFECTIVENESS As part of Metro's Water Quality School Program, a 2/3 -time staff person travels to schools and presents a half-day general water quality workshop including a section on HHW. Children are encouraged to take home a worksheet that helps them identify hazardous products in their home. After parents sign a form acknowledging that the "toxics hunt" assignment was completed, students receive a "Clean Team" pin. Participation in the home hunt is about 65-70 percent. Metro does not have enough staff to meet the current demand for presentations. "Sleuth," a full-length curricula developed by Metro in 1982 and distributed by the Office of Environmental Education, is still used and requested and has been reprinted several times. The Ecology's Litter and Recycling section devotes two full time staff to teacher training in solid waste issues. This program includes some information on HEW. A-17 s HOUSEHOLD HAZARDOUS WASTE COLLECTION AND WASTE ' HANDLING PROGRAM ELEMENTS HHW PERMANENT COLLECTION FACILITIES Permanent collection facilities provide citizens with a convenient place to dispose of their , household hazardous wastes. The facility itself would be any type of structure that is in compliance with local regulations. Permanent collection facilities would be staffed with ' trained personnel, open year round and sited for maximum accessibility. They can be sized to handle any volume of waste, depending on size and density of local population, available disposal capacity or other factors. Wastes collected would be separated and stored until they are transported to a licensed TSD facility by a licensed hauler. The method of waste handling and disposal after collection would be negotiated between site operators and the TSD. WASTE MANAGEMENT PRIORITIES Collection facilities provide citizens with a disposal option for HHW. Recyclable items, such as waste oil or batteries that are collected can be easily recycled or treated, promoting the state's highest waste management priority. Collection facilities also provide an opportunity for educating people about alternatives to hazardous products, thereby reducing the amount of waste generated. ENVIRONMENTAL AND HEALTH ASSESSMENT Sanitation workers run the risk of exposure to hazardous substances when HHW is mixed with municipal solid waste. By separating these wastes, collection facilities reduce the 11 r chances of these accidents. On the other hand, HHW collected in large quantities present the risk of exposure to the workers who handle them. When the wastes are collected and stored in an orderly fashion, workers can be trained to handle them safely. HHW that accumulates in peoples basements and garages increase the risks of exposures and fires. Collection facilities allow householders to remove these items, reducing these risks. There are risks associated with transport of the waste to the facilities; householders run the risk of spills or exposure in the case of a spill. In no collection options are provided, the wastes remain in people's garages and basements or are disposed of in the municipal garbage, poured down the drain or onto the ground. All these methods of disposal have environmental and health implications. Collection .r facilities mitigate these risks by providing an alternative disposal option. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS .. Collection facilities are compatible with existing programs and other programs under consideration in this plan. A-18 M M COST Costs are dependent upon program design and will vary considerably. Start up costs for the City of Seattle pilot project are: Site design and preparation $20,000 Hazardous waste shed 50,000 Equipment* and permits 5,000 .. Training 10,000 Planning and administration 20,000 Staff 34,000 per FTE �.. Disposal 1,300 per ton LEGAL ISSUES .. Since HHW is exempt from federal and state hazardous waste regulation, the only laws and regulations that apply to the program are for temporary storage of hazardous materials. Collection facilities must comply with local fire and building codes. (Under current fire .. and building codes, no distinction is make between a hazardous "waste" and a hazardous "material".) Collection facilities can help localities meet state "minimum functional standards" for diversion of hazardous waste from the solid waste stream. Despite the fact that HHW are exempt under state and federal hazardous waste laws, collection facility sponsors do not escape long term liability under Superfund for their contribution to ultimate disposal sites. However, this liability may be less onerous for local governments than the potential liability if a municipal solid waste landfill becomes a Superfund site because of mishandled household hazardous waste. POTENTIAL BARRIERS Cost is the primary barrier to implementing a collection facility. As Seattle's experience demonstrates, start up costs for a relatively small (though full service) facility are significant. Disposal costs are substantial. Permanent collection facilities require space. Adequate room must be available for storage of hazardous waste, a buffer zone around the storage facility for fire prevention purposes, room for queuing the cars. King County Solid Waste Division considers the volume of traffic at its transfer stations too great to accommodate the increased activity from a collection facility for HHW. Collection facility sponsors may find it inconvenient to accept certain wastes that are difficult to dispose of such as dioxin containing wastes or unidentified wastes. DEMONSTRATED EFFECTIVENESS In Washington, the City of Seattle set up a facility at the city's south Transfer Station. Thurston and Whatcom Counties sponsor small scale HHW collection /facilities. Chempro, a Seattle -based TSD offers a free collection and disposal service for HHW, one day a week. San Francisco, San Bernardino, Santa Monica and other California localities also have household hazardous waste facilities. Anchorage, Alaska is developing a collection facility. A-19 n HHW MOBILE COLLECTION FACILITY A mobile HHW collection facility would provide citizens living in areas of the County not served by permanent facilities with an accessible disposal option. A portable facility, a shed or container, would be transported to convenient locations on a schedule. The collec- tion facility would be set up and operated for two to four weeks in a single location, then moved on to the next scheduled stop. Stops would be chosen based on accessibility, safe transportation of wastes, land use and zoning and similar considerations. All local permitting requirements and safety regulations would be followed. Worker safety and emergency response training would be required of all site personnel. Wastes would be removed from the site as needed, by a licensed transporter or TSD firm. Wastes handling and disposal methods would be negotiated by the facility operators and the hazardous waste disposal firm. WASTE MANAGEMENT PRIORITIES This is a collection program. Collected wastes would be managed according to the state priorities, when possible. ENVIRONMENTAL AND HEALTH ASSESSMENT Collection diverts HHW from municipal waste streams and removes wastes from long-term storage, contributing to improved environmental quality, public and worker safety. Facility staff may risk exposure to HHW. These risks can be mitigated by emphasizing safety in facility design, worker training and operating procedures (including providing personal protective equipment when needed). COMPATIBILITY WITH EXISTING PROGRAMS Mobile collection complements other education and collection programs by providing HHW disposal options to citizens in rural areas of the county. COST Per Facility: Staff (based on operating hours) Truck rental Collection Shed Berms, fencing Set Up Permits and equipment Disposal costs 34,000 per FTE 5,000 25,000 4,300 7,600 4,000 1,300 per ton LEGAL ISSUES Local land use, building and fire codes must be followed in each jurisdiction hosting a facility. POTENTIAL BARRIERS Meeting some code -requirements, may be difficult and expensive. Siting difficulties. t M M • M .r M .n M W .r ■o A-20 so L HHW PICKUP SERVICE FOR THE HOMEBOUND r This program would provide a HHW collection service for residents, such as the elderly or disabled, who are unable to commute to a collection facility. Community service groups such as Community Home Help, chore services, and others would be contacted and encouraged to include collection and disposal of their client's unwanted hazardous products as part of their services. Field personnel or volunteers in these programs would dispose of wastes at local HHW collection services. These personnel would be given brief training on the safe handling and transport of HHW. WASTE MANAGEMENT PRIORITIES This program will promote proper disposal of HHW. ENVIRONMENTAL AND HEALTH ASSESSMENT Hazardous wastes would be diverted from the waste stream and removed from long-term storage in the garages and basements of an especially vulnerable segment of the population, �. reducing risks to public health and the environment. Exposure risk to volunteer staff is similar to that of a householder bringing wastes to a collection facility or a roundup. r COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS This program would be an extension of existing services provided to the homebound. This program would complement other proposed HHW collection programs by providing ., disposal options to an additional segment of the population. go an DEMONSTRATED EFFECTIVENESS A pilot program in San Diego collected HHW from 25 homes per day. Santa Monica offered pickup service for the homebound in conjunction with a roundup; 35 pickups were made during the one time event. A-21 M TARGETED WASTE COLLECTION AND RECYCLING M PAINT RECYCLING This program element addresses methods for handling paint "wastes" after they have been •. collected. The goals of the paint recycling project are: a) to investigate methods for recycling both .. latex and solvent -based paints; b) where recycling proves feasible, to implement recycling programs for paints collected as household hazardous wastes; and c) where recycling is not feasible, to investigate alternative disposal methods. .r Currently, paints are disposed of by landfilling or incineration, the lowest waste management priorities. Latex paints are generally not highly toxic (with the exception of some old lead-based paints, and paints that contain mercury as a fungicide). Solvent -based paints contain recoverable materials such as solvents and metal pigments. Latex recycling involves mixing the collected paints into a reusable paint product that can be sold at low cost. Recycling for solvent -based paints involves recovering solvents and metal pigments. .rr The private sector (paint manufacturers) would be involved in the actual preparation of the recycled latex paint. Incentives that are necessary for private sector involvement include: so 1) a potential market for the product; 2) adequate profit margin; and 3) support and assistance from the agencies involved in collection of latex paint. Reduced disposal costs make paint recycling an attractive program to agencies responsible for disposal of large 10 volumes of collected paint. The value of the recoverable materials from solvent -based paints may make solvent -based paint recycling a profitable option as well. STATE WASTE MANAGEMENT REQUIREMENTS This program is an attempt to manage a significant portion of the collected household wastes at a higher priority level than is currently done. ENVIRONMENTAL AND HEALTH IMPACTS Workers involved in paint collection and reprocessing will be exposed to the waste, but .r with adequate equipment and safety precautions, dangers are minimized. Recycling wastes rather than land disposal or incineration is beneficial to the environment. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS Collection facilities and programs will be a major contributor of paint wastes. This program No is a method of handling the collected wastes in a safer and more cost-effective manner. It will benefit the entire collection program. The City of Seattle Solid Waste Utility is conducting a pilot paint recycling project. No A-22 .s w LEGAL ISSUES There are some legal questions that are being investigated in the pilot phase, especially in relation to the recycled latex paint product. Areas that need to be investigated before the product can be marketed on a large scale include: 1) product labeling; 2) product quality; and 3) manufacturer responsibilities. POTENTIAL BARRIERS The potential barriers to paint recycling are technical feasibility; economic feasibility; institutional acceptance by paint manufacturers; and product marketability. r DEMONSTRATED EFFECTIVENESS Preparation of a recycled latex paint has been done on a small scale in California. Detailed feasibility and implementation questions were not fully addressed. Recovery of r. solvents and metal pigments from solvent -based paints is not a new technology, but use of these processes for small quantities of different types of products has yet to be tested. HOUSEHOLD BATTERY COLLECTION AND RECYCLING �. An estimated 17 million household batteries are purchased and disposed of annually in King County. This program would provide an alternative disposal option other than the solid waste stream. Under this program, household batteries would be collected and ,,.. recycled. Collection would take place at shopping centers, transfer stations and other appropriate locations. Receptacles would be distributed and batteries periodically picked up. we WASTE MANAGEMENT PRIORITIES This program emphasizes recycling. ENVIRONMENTAL AND HEALTH ASSESSMENT The heavy metal content of household batteries can cause contamination of leachate from landfills and ash from incinerators. Reducing the number of batteries in the waste stream will reduce potential environmental contamination from heavy metals. COMPATIBILITY WITH EXISTING PROGRAMS This program would be compatible with existing solid waste recycling programs. COST Project design $15,000 ` Implementation (publicity, outreach, staff training) $30,000 LEGAL ISSUES None. Is POTENTIAL BARRIERS Markets for recycled batteries would have to be investigated. 1 A-23 L DEMONSTRATED EFFECTIVENESS Japan has a very successful national battery recycling program. The Thermal Reduction so Co. in Whatcom County has a household battery recycling program that accepts mercury oxide and silver oxide button cell batteries. The batteries are collected and sent to Albany, New York and Lake Oswego, Oregon for recycling. go AUTO BATTERY COLLECTION/RECYCLING PROGRAM 1W Local programs will be developed to implement a new state law requiring a deposit on all lead -acid batteries when the Department of Ecology promulgates specific regulations for to this law. Programs to investigate potential markets for used lead -acid batteries would be encouraged. so WASTE MANAGEMENT PRIORI'T'IES A deposit system would encourage recycling of lead -acid batteries. .r ENVIRONMENTAL AND HEALTH ASSESSMENT Each lead -acid battery contains 1 gallon of lead -contaminated sulfuric acid. Ecology estimates that 25% of the 1,2000,000 used batteries generated each year are unaccounted for. Reducing the number of batteries entering the municipal waste streams improve worker and environmental health. COMPATIBILITY WITH EXISTING PROGRAMS Three of five battery manufacturers in the state have programs for recycling. The battery industry interest group, Battery Council International, has developed model legislation on go battery recycling and supports a program that enhances the existing recycling chain. LEGAL ISSUES Lead acid battery recycling is not exempt from federal Superfund liability. POTENTIAL BARRIERS The recycling of batteries is dependent upon foreign markets, which must be assessed. DEMONSTRATED EFFECTIVENESS no Rhode Island has a deposit on car batteries since 1987. Minnesota and California passed similar state legislation in 1988 that bans batteries from municipal landfills, requires retailers to accept used batteries and recycle them and to post signs to alert customers of No the landfill ban. A-24 r COLLECTION OF USED MOTOR OIL If feasible, used motor oil would be picked up from residences a) during normal collection of garbage or recyclables, or b) by separate contractor. Residents would leave oil out for +� collection in any unbreakable, leak -proof, closed container. Non -conforming containers would not be picked up. Special containers could be provided on request or made available at stores where oil is sold. Oil would be picked up and transported in a separate contained compartment of the collection truck. Individual containers would be carried to a central location for consolidation or the oil could be poured into containers on trucks. Collected oil would be screened for potential contamination with halogenated solvents, PCBs or other materials that would cause the used oil to be classified as a hazardous waste. Uncontaminated oil would be transferred to large holding tanks and picked up by a recycler. Contaminated oil would be managed as a hazardous waste. WASTE MANAGEMENT PRIORITIES This is a collection and recycling program. ENVIRONMENTAL AND HEALTH ASSESSMENT The potential for spills during collection and handling could be limited by careful handling practices and containment on trucks and at bulking and storage areas. There is a potential for vandalism of containers waiting for collection. The net result of the program would be to capture both oil and hazardous constituents that are currently entering the environment in an uncontrolled manner. COMPATIBILITY WITH EXISTING PROGRAMS This program would be compatible with solid waste collection systems operated by city agencies. Unincorporated areas of King County contract out their collection services to private haulers and would have to negotiate additional services with the haulers. Ecology is supportive of curbside pickup, and could provide some technical assistance in development and evaluation of the program. LEGAL ISSUES King County's ability or inability to contract directly for curbside collection services. Hazardous waste generator status for collection company may be necessary. Potential liability for oil spills, and for management/disposal of material that turns out to be hazardous waste. This would be largely a liability for the collection company. Careful contract provisions and oversight regarding proper containment, procedures, etc. would limit, but not eliminate, agency responsibility. M Insurance negotiations. an A-25 W BARRIERS Serving apartments may be difficult. Hazardous waste issue can deter collectors. May not be feasible for King County given collection regulations. DEMONSTRATED EXPERIENCE An oil collection program has been established in Milpita, California. The service reportedly reduces the incidence of worker injury and truck cleaning costs. A-26 0 SQG EDUCATION AND TECHNICAL ASSISTANCE PROGRAMS .. SQG INFORMATION DEVELOPMENT AND OUTREACH An information and outreach program would inform SQGs about proper handling and disposal of hazardous waste, current applicable regulations, and waste reduction. The program would also promote collection services. Written materials for specific industries or specific waste types would be distributed using a variety of methods, including the SQG information telephone line, resource library, trade associations, the media, and waste handling companies. The program has two sub -elements: EDUCATIONAL MATERIALS DEVELOPMENT: Materials explaining SQG waste reduc- tion and recycling options would be developed and distributed. Materials would be ' industry and waste -stream specific, with an emphasis on practicality of implementation. SEMINARS AND WORKSHOPS: Seminars and workshops would inform SQGs of waste reduction and recycling opportunities, providing the chance to share information and obtain answers to technical questions. In order to encourage participation, confidentiality would be protected, and no compliance or enforcement authorities would be involved. Events could be sponsored by trade associations or consultants with no connections to enforcement agencies to ensure SQG participation. WASTE MANAGEMENT PRIORITIES Outreach and educations efforts provide the information businesses need to follow the waste management priorities to the greatest extent possible. ENVIRONMENTAL AND HEALTH ASSESSMENT This program encourages the proper management of hazardous wastes, which positively affects worker, public and environmental safety. COMPATIBILITY WITH EXISTING PROGRAMS The SQG information and outreach program is compatible with existing education programs sponsored by Metro's Industrial Waste Section, the Health Department, Ecology, the • Hazardous Waste Interagency Coordinating Committee, and industry association efforts. The proposed program would enhance and expand existing programs. COST Educational Material Development Staff 0.5 FTE $20,000 Newsletters, brochures 75,000 Seminars and Workshops 25,000 Staff 1.0 FTE 40,000 Admin/supplies 10,000 LEGAL ISSUES .. None. A-27 Im POTENTIAL BARRIERS Government interference with private sector hazardous waste market. so rl DEMONSTRATED EFFECTIVENESS at The Seattle/King County Department of Public Health's Hazardous Waste Disposal: A Guide for Businesses booklet has been well received. W SQG PASSIVE WASTE EXCHANGE .r In a passive waste exchange, a broker acts as a clearinghouse for unwanted hazardous products, matching up businesses that have such products with those that can use them. The broker never takes possession of the wastes, but acts as a referral service through a phone line or a newsletter. A feasibility study will be conducted in 1989 by the Health Department. Results of this study will determine the best implementation strategy for this program. WASTE MANAGEMENT PRIORITIES .. This program emphasizes waste reduction, the state's top waste management priority, in that hazardous products are used up, rather than being disposed of. ENVIRONMENTAL AND HEALTH ASSESSMENT Participants in the waste exchange run some risk of injury from exposure to hazardous materials. Wastes would be transported either by the donor or the recipient; risks to health and the environment are similar in this instance to SQGs transporting wastes to collection sites or TSDs. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS The feasibility study would determine whether a waste exchange geared to the needs of SQGs would be compatible with existing programs and plans. COSTS Staff 1.5 FTE $57,000 Admin/supplies r 13,000 Phones/mist 5,000 Printing/mailing 20,000 .. LEGAL ISSUES Liabilities for both donors and recipients for wastes handled. Status of SQG wastes as "hazardous" when traded or donated to a business that can use them would have to be clarified. M POTENTIAL BARRIERS Business concern about contamination of wastes and quality control in industrial processes. A-28 r SQG TELEPHONE INFORMATION LINE Telephone lines provide businesses with the latest information on proper storage, handling and disposal of their hazardous waste. The trained staff would give referrals and .. information on regulatory issues, product alternatives, manufacturer information, legal assistance and any other relevant topics of concern. Information would be available to phone staff through the Resource Library (see Program Element: Resource Library). WASTE MANAGEMENT PRIORITIES Phone lines promote proper handling of hazardous wastes and can provide users with information emphasizing the State's higher waste management priorities. ENVIRONMENTAL AND HEALTH ASSESSMENT ,. The information provided businesses concerning the handling of SQG hazardous waste can include recommended procedures that minimize risk and promote public and worker safety. I 11 t COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS Phone lines provide publicity and information about other SQG programs and events. COST Costs would be dependent on the number of trained staff answering the phone line. Costs for a 1 FIE program are: Staff (1 FIB including benefits) $40,000 Administration and supplies 10,000 Rent 600 Telephone 1,000 Miscellaneous Supplies 400 LEGAL ISSUES Liability issues concerning the types of information given to business over the phone. POTENTIAL BARRIERS None. DEMONSTRATED EFFECTIVENESS The Health Department Hazard Line has averaged over 735 calls per month for January -July, 1988. Ecology's Hazardous Substance Information Line has responded to 550 calls/month thus far in 1988. A-29 SQG RESOURCE LIBRARY A local SQG library would provide SQGs with a wide variety of information on handling their hazardous wastes. The SQG library in King County would be a branch of the state-sponsored SQG Resource Center in Olympia, Washington. Materials specific to King County would supplement those available through the state-sponsored library. Literature, case studies and expert contacts for waste reduction, recycling and treatment, as well as worker safety and health, would be available. Requests for information will be made through the SQG Telephone Information Line. WASTE MANAGEMENT PRIORITIES This program would provide information to encourage SQGs to reduce their wastes, use alternative processes and products, and at a minimum, use appropriate disposal methods for wastes that are generated. ENVIRONMENTAL AND HEALTH ASSESSMENT Information is essential to the appropriate management of hazardous wastes. When these wastes are managed and disposed of carefully, public health and the environment benefit. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS This program would be a "satellite" of the Ecology library; as such, it is an expansion of an existing program. It is recommended that the Ecology library continue to receive funding. Having these information resources locally available would also increase the ability of the SQG Telephone Information Hotline to answer SQG questions. COSTS Staff 1.0 FTE Admin/supplies Materials and Data acquisition Computer system LEGAL ISSUES None. YEAR 1 YEAR $40,000 $40,000 10,000 10,000 10,000 20,000 15,000 5,000 POTENTIAL BARRIERS Finding technical information appropriate for SQGs. An agreement with the resource center in Vancouver would have to be negotiated. Continued state sponsorship of the existing program is not certain. DEMONSTRATED EFFECTIVENESS The Intergovernmental Resource Center (IRC) operated a SQG Technical Resource Center in Vancouver, Washington during 1988 with funding from Ecology. The service was successful in creating an awareness of disposal options and waste reduction options for SQGs. Ecology has since taken over the service. A-30 Nd so M M as M so r .r 1 W W e PROMOTION OF SQG WASTE REDUCTION, RECYCLING AND TREATMENT M PROGRAMS Under this program, the research and development of waste reduction, recycling and treatment technologies by industry, private and public research and development labs, and universities would be enhanced. Programs include: r.0 A needs assessment to identify priority waste streams, to be conducted by a broad- based technical advisory committee; • Waste stream analyses and development of prototype waste profiles for SQG waste .• streams; • Loans, grants or awards to encourage private development of new waste reduction processes or technologies; • Internship programs or development of endowments for research assistantships for chemistry, engineering and related science graduate students to test new products and technologies for waste management; • A newsletter for exchanging technical information, ideas and discussing problems; • Pilot projects to determine the feasibility of various waste reduction, treatment or recycling methods. Government _agencies could conduct pilot projects. Many .. government agencies such as parks department, utilities, school districts are generators of hazardous wastes. These entities could develop and implement programs to reduce their own wastes using methods and strategies that could be copied by SQGs. Examples of such programs include Integrated Pest Management instead of pesticide use in parks, utility rights-of-way and other areas; substitution of less hazardous products in government shops and garages; agency -wide purchasing policies and programs that choose non -hazardous products over hazardous ones; or consolidating solvent wastes, for example, for in-house treatment and recycling. WASTE MANAGEMENT PRIORITIES This program emphasizes waste reduction, the top state priority for waste management. It also encourages waste treatment and recycling. .. ENVIRONMENTAL AND HEALTH ASSESSMENT Less waste would be produced, therefore, directly and positively affecting worker health and environmental safety. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS These waste reduction projects complement federal small business loans and grants ` programs. They also complement small informal discussion groups such as the University of Washington's "lab group" which shares information and discusses technical issues. The Puget Sound section of the American Chemical Society would like to enhance the promotion of chemical careers by getting involved with waste reduction technologies. This program element provides the up-to-date information required for the success of other recommended program elements: Information Telephone Hotline, SQG Resource Library, seminars and workshops, and On -Site Consultation. A-31 W COST Staff (per FTE) Admin/supplies Needs assessment Waste stream analysis Newsletter and technology transfer Incentive/awards program YEAR 1 YEAR 2 0,40,0 1 40,00 10,000 10,000 10,000 20,000 20,000 209000 1 60,000 20,000 50,000 LEGAL ISSUES There are no legal issues associated with this program. POTENTIAL BARRIERS Trade secrets and patents could inhibit the free exchange of information. Certain local codes may present barriers to the on-site treatment of wastes. DEMONSTRATED EFFECTIVENESS North Carolina has a 'Pollution Prevention Pays" program that provides grants and loans to businesses to institute waste reduction. The Minnesota Technical Assistance Program (Mn TAP) coordinates an internship program with the University of Minnesota. Illinois has a Hazardous Waste Research Institute. SQG WASTE CHARACTERIZATION AND TREATMENT FEASIBILITY Under this program, government would: • identify SQG waste streams that contribute hazardous wastes to municipal waste streams; • characterize those waste streams; • identify treatment technologies that would make it possible to dispose of these wastes in municipal waste streams rather than as a hazardous waste. Businesses that generate candidate waste streams include jewelry businesses, small metal plating businesses and photo processors (metal recovery, pH balancing and cyanide detoxification). Where proven feasible, treatment technologies would be tested, and the private sector would be encouraged to use these treatment processes. WASTE MANAGEMENT PRIORITIES Treatment of wastes is emphasized. ENVIRONMENTAL AND HEALTH ASSESSMENT This program would identify additional SQG waste streams for treatment and would increase the proportion of treated wastes entering the municipal waste streams. The [i M Im M r .r r .r M .n as no so A-32 ad r rr environment would be positively affected by reducing the amount of hazardous wastes entering the environment. COMPATIBILITY WITH EXISTING PROGRAMS .• By decreasing the toxicity of wastes entering the municipal waste streams, this program would help sewage treatment plants meet discharge limitations and lower leachate toxicity at solid waste facilities. COSTS Staff YEAR 1 YEAR 2 «. Planning & management 1.0 FTE $45,000 45,000 Operations & analysis 1-2.0 FTE 0 45,000 Equipment 0 150,000 .,. Lab analysis 0 40,000 Admin/supplies 20,000 22,500 ., LEGAL ISSUES Any necessary permits would have to be obtained. Whether a pilot treatment facility would require a Part B permit would have to be determined. POTENTIAL BARRIERS Technical feasibility. Business unwillingness to participate. SQG ON-SITE CONSULTATION This program would provide businesses with the opportunity to request an On -Site Consultation on hazardous waste management. Experts would walk through the business, provide information on environmental compliance and help establish best waste management practices specific to that business. This would be a consultation program only, and would not be linked to any inspection/enforcement program. If the on-site visit exposes an illegal amount of stored waste (i.e., more than 220 pounds), but the business otherwise qualifies as a "SQG", the business would be given a grace ` period to dispose of their wastes without enforcement penalties. The grace period would be given one time only, after which proper waste management is required. This program is similar to the SQG Audits and Surveys but, since there is no referral or enforcement/compliance component, it allows businesses the opportunity to receive direct assistance the first time without enforcement and penalties. It is estimated that one FTE field staff will contact an average of 75 SQGs per year. This includes actual on-site review, research and follow-up time. WASTE MANAGEMENT PRIORITIES The program emphasizes waste reduction efforts, the DOE's highest waste management priority. A-33 gr ENVIRONMENTAL AND HEALTH ASSESSMENT .■ This program fosters best waste management practices and so, positively affects health, worker and environmental safety. no COMPATIBILITY WITH EXISTING PROGRAMS This program is compatible with other proposed SQG education and technical assistance programs. .r .KSI. DEMONSTRATED EFFECTIVENESS 8W The Department of Labor and Industry provides a non -enforcement on-site consultation service to businesses upon request for worker safety regulations. A-34 r M an 77 rr J �J 77 IN YEAR 1 YEAR 2 .r Staff (coordinator - 1.0 FTE) $40,000 $40,000 Staff (field - 4.0 FTE) 80,000 120,000 Supplies 30,000 52,000 ., Vehicles 20,000 23,000 LEGAL ISSUES Liability for providing technical recommendations. POTENTIAL BARRIERS W None. DEMONSTRATED EFFECTIVENESS 8W The Department of Labor and Industry provides a non -enforcement on-site consultation service to businesses upon request for worker safety regulations. A-34 r M an 77 rr J �J 77 IN 7 i SQG COLLECTION AND WASTE HANDLING PROGRAM ELEMENTS SQG MOBILE COLLECTION FACILITIES A mobile collection facility would be set up in a convenient location where SQGs could bring their wastes for a designated period of time. SQGs would complete the appropriate paperwork and waste profiling prior to bringing the wastes to the collection site. Facilities would consist of a commercial step -van or trailer truck used to transport equipment to the temporary collection site and store wastes until they are removed by a licensed hazardous waste hauler. The collection facility would be equipped with all appropriate safety features as required by the local fire departments and permitting agencies. Under this program, local governments would subsidize the collection facility for five years. The facilities would be operated by licensed hazardous waste facility personnel. After the five year period, hazardous waste handling companies would be given the option .. to assume full operation of the facility. WASTE MANAGEMENT PRIORITIES The waste handling firm's contract with government would emphasize preferred management alternatives for the collected wastes such as recycling and treatment. ENVIRONMENTAL AND HEALTH ASSESSMENT Environmental health benefits increase as wastes are properly managed. There may be a potential for spills during transport of wastes to the mobile facilities. Precautions can be taken to ensure safe transport of wastes. COMPATIBILITY WITH EXISTING PROGRAMS AND PLANS A mobile collection facility augments private sector disposal services with assistance from government. COST Costs FOR 1 SITE: Staff (3 FTE/site) $105,000 Trucks (5 year lease) 100,000 Equipment,berms and fencing 10,000 Set-up costs 5,000 • Planning and Training 25,000 LEGAL ISSUES +� A mechanism must be instituted to ensure that only wastes from small quantity generators are accepted. Liability for the wastes would have to be assessed. A-35 1 rl t r so APPENDIX B TECHNICAL INFORMATION B-1 TABLE OF CONTENTS .o r an FACILITY SITING ..................................... B-2 .. LEGAL DEFINITIONS OF HOUSEHOLD AND SMALL QUANTITY GENERATOR HAZARDOUS WASTE ......................... B-2 ,., TONNAGE PROJECTIONS ................................ B-2 HOUSEHOLD HAZARDOUS WASTE REDUCTION ASSUMPTIONS .... B-3 SMALL QUANTITY GENERATOR PROGRAM ASSUMPTIONS ....... B-5 HHW AND SQG WASTE REDUCTION, RECYCLING AND DISPOSAL GOALS............................................ B-6 BUDGET ASSUMPTIONS ................................ B-8 ADOPTION PROCESS ................................... B-9 r REFERENCES ........................................ B-9 EXAMPLES OF FACILITY SITING .......................... B-10 BUDGET SUPPLEMENT ................................. B-16 COORDINATOR JOB DESCRIPTIONS ........................ B-30 1990 STAFFING COMMITMENTS ........................... B-32 +.w INTERLOCAL AGREEMENT .............................. B-33 SUPPLEMENT TO APPENDIX D (PUBLIC INVOLVEMENT DOCUMENTS) D-1 .o r an .. . TECHNICAL INFORMATION so B-2 •+ FACILITY SITING Zoning requirements for hazardous waste collection facilities are still being written in compliance with RCW 70.105. The deadline for local governments to complete this process has been extended to November, 1991. It is most likely, however, that these facilities will be treated under the conditional use sections of local zoning codes. The zoning requirements for Cities of Bellevue and Seattle begin on page B-10. LEGAL DEFINITIONS OF HOUSEHOLD AND SMALL QUANTITY GENERATOR HAZARDOUS WASTE TONNAGE PROJECTIONS Washington State regulations (WAC 173-303) define household hazardous wastes as follows: "Household Hazardous Wastes" means any discarded liquid, solid, contained gas, or sludge, including any material, substance, product, commodity, or waste, used or generated in the household, regardless of quantity, that exhibits any of the characteristics or criteria of dangerous waste set for in Chapter 173.303 WAC. Washington State Department of Ecology has developed rules explaining how generators of regulated hazardous waste can determine whether the wastes they generate are hazardous or not (WAC 173.303). If they are hazardous wastes, they must be handled, sorted and disposed of according to the provisions of the regulations. Ecology defines Small Quantity Generator Hazardous Wastes as: any discarded liquid, solid, contained gas, or sludge, including any material, substance, product, commodity, or waste, used or generated by businesses that exhibits any of the characteristics or criteria of dangerous waste set for in Chapter 173.303 WAC, but which is exempt from regulation as dangerous waste. The base tonnage generated in King found in the King estimate for the quantity County (including the City County Programmatic Draft of solid waste of Seattle) is Environmental r, .r J 11 M APPENDIX B TECHNICAL INFORMATION B-3 Impact Statement -- Solid Waste Management Alternatives (June 1988). These base estimates do not take into account solid waste recycling or reduction programs. Solid waste •• tonnage projections are summarized in Table B-1: M Table B-1. SOLID WASTE TONNAGE PROJECTIONS Year Tonnage 1994 1,836,000 1999 2,106,300 2009 2,818,600 The HHW and SQG tonnage projections used in this Plan are derived by applying the following assumptions to the base tonnage estimate for solid waste quantities in King County through the year 2009, assuming the existence of no local programs to address these wastes. HHW and SQG hazardous waste tonnage projections are presented in Figure 2-7. 80 to 85 percent of the HHW in municipal waste streams is found in the solid waste stream. The remaining 15 to 20 percent is disposed of in the sanitary sewer system. For waste projection purposes, an 85/15 split is assumed. In addition, an unquantifiable amount is disposed of directly into the environment, via storm drains or direct dumping onto the ground. HHW in the King County solid waste stream is 33 percent of the total hazardous waste in municipal waste streams. SQG waste accounts for the remaining 67 percent. HOUSEHOLD HAZARDOUS WASTE REDUCTION ASSUMPTIONS Reduction percentages are the result of an item by item analysis of the types of hazardous wastes typically found in the King County waste stream. The Technical Planning Committee then used its collective best professional judgement, using the MW dw APPENDIX B TECHNICAL INFORMATION B-4 I following assumptions to project by what percentage a given ad waste stream can be reduced within a specific timeframe (Table B-2). .r Table B-2. REDUCTION GOALS FOR HHW, BY WASTE TYPE .r Waste Tvne 1990 1994 1999 2004 2009 r Latex Paint 0% 8% 58% 73% 73% Oil -Based Paint 0% 8% 42% 55% 55% Used Oil 0% 0% 0% 10% 10% Pesticides 0% 4% 41% 55% 55% Solvents 0% 0% 20% 32% 32% «i Corrosives 0% 4% 41% 55% 55% Aerosols 0% 4% 49% 64% 64% Waste stream specific assumptions are listed below: r Latex Paint. As a result of education programs, people will: make better estimates of how much they need for a particular job, and buy less; give away left overs; dry out residues and put in the trash. As a result of education and promotion of alternative purchasing practices, people will buy smaller cans when they only need a little bit. Paints that need not be handled as hazardous wastes will be identified and disposed of in alternative ways. Newer paints will contain fewer and fewer hazardous ingredients. Oil-based Paint. As a result of education programs, people will: make better estimates of how much they need for a particular job, buy less, and give away left overs; use latex paint wherever possible. As a result of education and promotion of alternative purchasing practices, people will buy smaller cans when they only need a little bit. Oil and Vehicle Batteries. Waste reduction in these categories is not possible at present. The top priority is recycling. Pesticides. As a result of education programs, people will: 0i have a better understanding of the potential hazards of excessive pesticide use; learn to use pesticides properly d APPENDIX B TECHNICAL INFORMATION B-5 (according to the label); buy smaller quantities; use alternative methods and safer products for pest management; become more tolerant of non -damaging pests. Solvents. As a result of education programs, people will: buy smaller quantities according to their need; learn to reuse some • solvents. Corrosives. As a result of education programs, people will: a) .,. buy alternative, safer products;buy smaller quantities according to their need. SMALL QUANTITY GENERATOR PROGRAM ASSUMPTIONS r Although there are fewer SQG businesses to reach than there are households in King County, these businesses contribute twice as much hazardous waste to municipal.waste streams. The following industries will be targeted for services, surveys and audits under the Plan: automotive repair, body and maintenance shops; dry cleaners; machine shops; marine repair facilities and boat yards; photoprocessors, printers, graphic artists, and lithographers; pesticide applicators; furniture repair and woodworking shops; medical, dental, veterinary, and other labs, clinics and offices; miscellaneous equipment repair and maintenance; circuit board manufacturers; metal platers; paint and coatings manufacture; and construction. Targeting specific industry types with detailed, directly applicable information will have greater impact than general activities. There are 101,000 businesses licensed in King County (Chisholm, personnal communication, 1988). Metro's Industrial ow Waste section has determined that approximately 32,000 of these generate some type of pollutant, based on SIC characterizations. Allowing for some inaccuracy in the assignment of SIC codes, for firms that are no longer in business, and for the number of companies that actually dispose of hazardous wastes in municipal waste streams, it is estimated the 20,000 businesses are SQGs in King County. A majority (up to 80 percent by some estimates) of the business licenses issued in King County fall within a ten mile radius of downtown Seattle. By some estimates, 96-98 percent rr APPENDIX B TECHNICAL INFORMATION 11 of the businesses in King County are considered small businesses (Puget Sound Council of Governments, 1988). The majority of small businesses generating hazardous wastes are SQGs, rather than fully -regulated hazardous waste generators. The Small Business Administration indicates that four out of every five small businesses fail within the first five years of operation. Additional companies will be started every year that need to get information for the first time and be introduced to available programs. Collection goals are based on best professional judgment and input form hazardous waste handlers and treatment, storage and disposal companies. The percentage breakdown of wastes by waste stream is based on survey data from the Health Department (Yerkes, et al., 1988) and a North Hollywood, California study (SCS Engineers, 1984). Table B-3 shows the percentage breakdown. Table B-3. SQG WASTE STREAM, BY WASTE TYPE WASTE TYPE Latex Paint Oil -Based Paint Used Oil Halogenated Solvents Non -Halogenated Solvents Corrosives Heavy Metal Sludge Other Wastes PERCENT OF WASTE STREAM 2% 2% 42% 9% 32% 4% 1% 8% r HHW AND SQG WASTE REDUCTION, RECYCLING AND DISPOSAL GOALS Waste reduction, recycling and disposal goals for HHW and , SQG waste, by waste type, are given on Tables B-4 and B-5. 1 t Table B-4. Types of Waste Latex Paint Oil -Base Paint Solvents Waste Oil Pesticides Vehicle Batteries Corrosives Aerosols Other Table B-5. HOUSEHOLD HAZARDOUS WASTE REDUCTION, RECYCLING AND DISPOSAL GOALS SMALL QUANTITY GENERATOR REDUCTION, RECYCLING AND DISPOSAL GOALS 1990 1990 RED 1994 1994 18% 1999 RED ED REC DISP RED REC DISP RED REC DISP 0% 4% 4% 6% 12% 12% 58% 20% 10% 0% 7% 0% 8% 24% 1% 420/6 38% 20/6 0% 7% 0% 0% 24% 1% 20% 57% 0% 0% 4% 2% 0% 120/. 5% 0% 72% 4% 0% 0% 8% 4% 0% 25% 41% 0% 40% 0% 50% 0% 0% 82% 0% 0% 86% 0% 0% 7% 0% 4% 24% 1% 41% 32% 7% 0% 0% 8% 4% 0% 25% 49% 0% 33% 0% 0% 8% 0% 0% 25% 0% 0% 75% SMALL QUANTITY GENERATOR REDUCTION, RECYCLING AND DISPOSAL GOALS s 9, RED 1999 1990 RED REC 1994 18% Types of Waste RED REC DISP RED REC DISP Latex Paint 0% 0% 0% 6% 4% 3% Oil -Base Paint 0% 0% 0% 8% 4% 0% Solvents 4% 4% 0% 36% 0% 36% Halogenated 0% 0% 0% 0% 8% 2% Non -Halogenated 0% 0% 0% 1% 9% 2% Waste Oil 0% 0% 0% 2% 9% 0% Adhesives 0% 0% 0% 1% 1% 10% Pesticides 0% 0% 0% 1% 1% 10% Corrosives 0% 0% 0% 10% 2% 1% Dioxins/PCBs 0% 0% 0% 1% 0% 11% Vehicle Batteries 0% 0% 0% 0% 11% 1% Heavy Metal Liquids 0% 0% 0% 5% 5% 2% Heavy Metal Sludges 0% 0% 0% 2% 1% 9% Other 0% 0% 0% 9% 3% 0% s 9, RED 1999 DISP RED REC DISP 18% 12% 10% 24% 14% 2% 10% 24% 6% 4% 28% 7% 6% 32% 2% 4% 4% 32% 4% 4% 32% 30% 6% 4% 4% 0% 36% 0% 36% 4% 16% 16% 8% 6% 6% 28% 28% 10% 2% s 9, RED 2004 DISP RED REC DISP 73% 23% 5% 55% 43% 2% 32% 68% 0% 10% 89% 2% 55% 0% 45% 10% 90% 0% 55% 36% 9% 64% 0% 36% 0% 0% 100% s 9, RED 2004 DISP RED REC DISP 36% 24% 20% 48% 28% 4% 20% 48% 120/6 8% 56% 16% 12% 64% 4% 8% 8% 64% 8% 8% 64% 60% 12% 8% 8% 0% 72% 0% 72% 8% 32% 32% 16% 11% 12% 56% 56% 20% 4% s 9, RED REC DISP 73% 23% 5% 55% 44% 2% 32% 68% 0% 9% 89% 2% 55% 0% 45% 9% 91% 0% 55% 36% 9% 64% 0% 36% 0% 00/0 100% RED REC DISP 45% 30% 25% 60% 35% 5% 25% 60% 15% 10% 70% 20% 15% 80% 5% 10% 10% 80% 10% 10% 80% 75% 15% 10% 10% 0% 90% 0% 90% 10% 40% 40% 20% 15% 15% 70% 70% 25% 5% .. 2NODIVNE' BUDGET ASSUMPTIONS TECHNICAL INFORMATION P_J M.- The budget for the Recommended Program can be found beginning on page B-16. The budget is arranged by component, and within each component, by program element. Administrative and coordination costs are indicated. The HHW components appear first, followed by the SQG components and the Evaluation component. The HHW Collection component budgeted is supplemented by additional tables providing detailed calculations of operating and disposal costs, levels of service, and amounts of waste collected and number of users served. These supplemental tables can be found on pages B- 28 and B-29. Salaries include benefits and are budgeted at the levels indicated in Table B-6. Job descriptions for the program coordinator positions can be found on pages B-30 and B-31. 1990 Staffing commitments for the five major implementing agencies are described on page B-32. Table B-6. BUDGETED SALARY LEVELS BY POSITION Program Coordinator $45,000 Field personnel $40,000 Education program $32,000 to $40,000 Collection program $34,000 10 W .W Administration and supplies: 30% of salary for collection personnel; 25% of salary for all other personnel. Vehicle costs: one new car at $20,000 per 2 FTE (field personnel); $1,500 per year operating cost per person. Per ton disposal cost is estimated at $682 for SQG wastes. Except for the disposal subsidy program, all disposal costs are the responsibility of the SQGs. Waste handling (disposal) is estimated at $1300 per ton for ' HHW. This figure is derived from experience at local Round- ups and the City of Seattle HHW Collection Facility at the South Transfer Station. Regulations governing hazardous waste M M APPENDIX B TECHNICAL INFORMATION B-9 �. treatment and disposal facilities are changing rapidly. Therefore, this figure can be expected to change over time. The mobile facilities, due to set-up and tear -down requirements, are assumed to be in operation 36 weeks per year, rather than the 52 weeks available to permanent facilities. ADOPTION PROCESS w. The Plan must be adopted by the various city councils and the County Council. For the suburban cities, the adoption process •• will use the Interlocal Forum, as described in Section 3. A copy of the agreement explaining the Interlocal Forum process can be found beginning on page B-32. REFERENCES ,,. Chisolm, Washington State Department of Revenue. Personnel Communication, 1988. Puget Sound Council of Governments. Population and Employment Forecasts, Seattle, Washington, 1988. SCS Engineers. Development of a Hazardous Waste Management Plan for Small Quantity Generators: North Hollywood Pilot Study Final Report Hazardous Waste Inventory. Southern California Association of Governments, Los Angeles, California, November, 1984. Yerkes, T.W., W.C. Swofford, S.A. Whitman, C. Thompsen, T. Clements. Surveys and Audits of Major and Minor Small Quantity Business Generators in the Seattle -King County Area, Seattle -King County Department of Public Health, Seattle, Washington, unpublished. M Im Office Of The Mayor City of Seatde Charles Royer, Mayor October 28, 1987 Earl Tower, Manager Solid and Hazardous Waste Program Department of Ecology Mail Stop Pv-11 Olympia, Washington 98504-8711 Dear Mr. Tower: In compliance with the requirements of the State Hazardous Waste Management Act (RCW 70.105), the City of Seattle has designated eligible zones for treatment and storage facilities for hazardous wastes. we have already met most of the specific requirements as outlined in the July, 1987 "Zoning Guidelines". We have included definitions of on-site and off-site treatment and storage facilities. Off-site treatment or storage of hazardous waste is permitted in industrial zones. On-site treatment and storage of hazardous waste is permitted as an incidental or accessory use in commercial or industrial zones. The specific language included in the Code is enclosed. At this time, we have not included the siting criteria in the Code because we want to wait until these criteria are finalized in order to determine how best to include them. Contingent upon Ecology finalizing these criteria in a timely manner, we will meet the final requirement before June 30, 1988. Compliance with the zoning designation requirements will be conducted independently of other local governments. we will be coordinating with King County and Metro in development of our Moderate Risk Waste Plan, however. Sincerely, Charles Royer Enclosure 6V • In bC o An equal emoloyment 000ortumty - affirmative action emcioyer 1200 Mumc oal Building, Seattle. wasn ngton 98104, 12061 625 4000 C so aw No i� r r a F I r I U. 1 9 i r f t t I I I I F. Production of parts to be assembled into a finished product. 7. Development of film on a wholesale basis. 8. Production of items through biological processes, such as pharmaceuticals and industrial purifiers, manufactured by bioengineering techniques. 9. Production of items such asap int and coatings, dye- stuffs, fertilizer, glue, cosmetics, clay, or pharmaceuticals that require the mixing or packaging of chemicals. "Manufacturing, Heavy_ means a manufacturing use, typically having theop tential of creating substantial noise, smoke, dust, vibration and other environmental impacts or pollution, and including but not limited to: 1. The extraction or mining of raw materials, such as quarrying of sand ccrg ave; 2. Processing or refining of raw materials, such as but not limited to minerals, petroleum, rubber, wood or wood pulp_ into other products; 3. The milling ofrg ain or refining of sugar, except when accessory to a use defined as food processing for human consumption or as a retail sales and service use; 4. Poultry slaughterhouses, including packing and freezing of poultry; 5. Refining, extruding, rolling_ or drawing of ferrous or non-ferrous metals, or the use of a non -induction foundary for ferrous metal; 6. Mass production of commercial or recreational vessels of any size and the production of vessels one hundred and twent feet (120') in length constructed to individual specifications; 7. Productioin of large durable goods such as motorcv- cles, cars manufactured homes, airplanes, or heavy farm, industrial, or construction machinery; 8. Manufacturing of electical components, such as semi- conductors and circuit boards, using chemical processes such as etching or metal coating; 9. Production of industrial organic and inorganic chemi- cals, and soaps and detergents; and 10. Conversion of solid waste into useful productions or preparation of solid waste for disposal of another location by processing to change its physical form or chemical composition. This includes the off-site treatment or storage of hazardous wgste as regulated by the State Department of Ecology. The on-site treatment and storage of hazardous waste is considered an incidental or accessory use. Section 14. Section 23.84.028 'O" of the Land Use Code is hereby amended to read as follows: "Open Space" means land and/or water area with its surface open to the sky or predominantly undeveloped, which is set aside to serve the purposes of providing park and recreation opportunities, conserving valuable natural resources, and structuring urban development and form. 'Open S ap ce, Recreational" means an outdoor area which is of appropriate size, shape, location and topographic siting, and 29OBc/DRAFT/Lou CITY OF BELLEVUE, WASHINGTON ORDINANCE N0. _ AN ORDINANCE relating to onsite and offsite hazardous waste storage and treatment facilities; amending Bellevue City Code (Land Use Code) 20 10,440 Transportation and Utilities Notes and Chart, 20 50 024. WHEREAS, in 1985 the Washington Legislature passed House Bill 975 N as amendments to Chapter 70.105 RCW, the State Hazardous Waste Management Act (the Act); and WHEREAS, in July, 1987 the State Department of Ecology published zoning gundalines which fulfill a requirement of the A.:t and make the legislative requirements mandatory; and WHLRFAS, on October 22, 1987 the City of Ballavue submitted to Cha Uepartment of Ecology a letter of intent to comply with zoning designation requirements for hazardous waste treatment and storage facilities by June 30, 1988, and WHEREAS, this ordinance reflects the state mandated requirements that hazardous a3te treatment 3,1.d storage facilities must be allowed in zones in which the handling and processing of hazardous substances is not prohibited, escept residential zones; and M M M M M M no WHEREAS, the City of Bellevue has complied with the State Environmental Policy Act and with the City's Environmental Procedures Ordinance; now, therefore, THF. CITY COUNCIL OF THE CITY OF BELLEVUE, WASHINGTON, DOES ORDAIN AS FOLLOWS: - Section 1. Bellevue City Code (Land Use Code) 20.10.440 Transportation and Utilities Notes and Chart are amended as follows: m m m 0 go m 0 w 12 Land Use Codr Chart 20.10.4.40 USES IN LAND USE DISTRICTS TRANSPORTATION & UTILITIES i�IC iC 1C IIIIIIiil�ll-IIIIIIII 6ocx vrnm s+srF+. ? P ? P p - Ixf=—:unVrr3KrFv ICICI -,IC IC ICICICLC1CICiC1CIC C1C1C1CICICI „� I �,�;-:��U°`°.�..•, ` _u�.,T 1 1 1 1 1 1. 1 1 1 1 1 1 1 I I I� I� I� I� I A I CF: — ..L C:'J: oAJ7-,_ ur T lr I I I I I I C Illillllil_Ilil 02'" 'ec �Se3 n 71! c'rtrsretn Mi9n13nC3 :ll:y _.Sa4: (S=.A. _-.E. -,_Z ANC Zr�C) are .+LC n EK'_'cn Z: 2! 010. Key P PSPiM17-)EC USE C • CrNCITICNAL USE (ste Pan 20, -CB PO - PS?.MIT-EC Iu C:eC :C 04rlmeo irit Jove-ccrr.ent crvv (ser Par, 20.1OC.) 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Wp•GiS ♦ WIU I I P C P re MW MlIvC?S I ( I I I I I ( I I I I I I I I I I I` I�wp3,r:a.c<s.uwt.,.—c ALM IC Ivl2CICICICICICICICICICICICICICICICI IA I I IZ AI i�IC iC 1C IIIIIIiil�ll-IIIIIIII 6ocx vrnm s+srF+. ? P ? P p - Ixf=—:unVrr3KrFv ICICI -,IC IC ICICICLC1CICiC1CIC C1C1C1CICICI „� I �,�;-:��U°`°.�..•, ` _u�.,T 1 1 1 1 1 1. 1 1 1 1 1 1 1 I I I� I� I� I� I A I CF: — ..L C:'J: oAJ7-,_ ur T lr I I I I I I C Illillllil_Ilil 02'" 'ec �Se3 n 71! c'rtrsretn Mi9n13nC3 :ll:y _.Sa4: (S=.A. _-.E. -,_Z ANC Zr�C) are .+LC n EK'_'cn Z: 2! 010. Key P PSPiM17-)EC USE C • CrNCITICNAL USE (ste Pan 20, -CB PO - PS?.MIT-EC Iu C:eC :C 04rlmeo irit Jove-ccrr.ent crvv (ser Par, 20.1OC.) A - ACMINISTriAT1VE C--NCMCNAL USE tsr_ Pan 20._Cc B-13 I�C!SSGty r•�au<G 1 r 1 P I P I P I P I P I I P I r l~ I P( r I r I I I P I r I r I I r I I I ? i= µ� A rjS j xwG.e .�I ;1 j 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I I f l -1 I? I^ 1=1 � I � I "A 1""`�°"�"_ IcIcI`IcIcIcIcIcIcIcIcIcIcI=IcIcIcIcIcI .r I _�rE73 ...G N� •�Fi I I I I ISI •1 I i l l l l l l l l l l l l l l l i l -1 I l l -1-1 r -1 c1cIcIcIcIc cIcIcIcIcIcIcIcicl IccIci_ ., 1;_:.•.ur.Ca,CNa.fiOr�t• 1.t... Apo S-Afl-W4nCF.&, i�IC iC 1C IIIIIIiil�ll-IIIIIIII 6ocx vrnm s+srF+. ? P ? P p - Ixf=—:unVrr3KrFv ICICI -,IC IC ICICICLC1CICiC1CIC C1C1C1CICICI „� I �,�;-:��U°`°.�..•, ` _u�.,T 1 1 1 1 1 1. 1 1 1 1 1 1 1 I I I� I� I� I� I A I CF: — ..L C:'J: oAJ7-,_ ur T lr I I I I I I C Illillllil_Ilil 02'" 'ec �Se3 n 71! c'rtrsretn Mi9n13nC3 :ll:y _.Sa4: (S=.A. _-.E. -,_Z ANC Zr�C) are .+LC n EK'_'cn Z: 2! 010. Key P PSPiM17-)EC USE C • CrNCITICNAL USE (ste Pan 20, -CB PO - PS?.MIT-EC Iu C:eC :C 04rlmeo irit Jove-ccrr.ent crvv (ser Par, 20.1OC.) A - ACMINISTriAT1VE C--NCMCNAL USE tsr_ Pan 20._Cc B-13 Land Use Code 13 NOTES: USES IN LAND USE DISTRICTS—TRANSPORTATION AND UTILITIES 1. Rail Transportation is limited to only Right -of -Way in OU districts. 2. Aircraft Transportation is limited to only Heliports in OU, CED -0-1, CSD -0.2 and CSD -OLS distric.s.1 3. Commercial lots and garages are those lots and garages which provide vehicular parking for the public generally for a fee and do not inc-lude lots and garages which provide the required parking for other uses. 4. Utilities: Local Storage, Distribution &Substations are rimited to those utilities serving orly the com- munity surrounding them as part of the storage and distribution network. All other utilities are c!assined Ublibes: Production, Generation, Disposal, Processing & Treatment Plants, Feyicnal Storage, 0 stribu- tion & Substations. 5. Permitted only as a subordinate use to a permiGed or special use in CED -O.1, CBD -C-2. CED -MU and CED -OLS dislunc.s. 5. The location of an ctf•site parking facility must be approved by the Direr or of Design and Develcp- i ment. See Section 20.25A.0501;. go (Ord. 2945, 2.2-82, Sec.icn 5) i 7. Park and Ride. A Park and Pool Lct or other carpool ,'aacility is re_ufa:ed as a park anc rice. A park and ride providing no more than °0 parkine spaces, and utilizinge parking area cf an exist -mg use shall be re_ulatec' as an accessory use uncer Secaon 20.20.200. Any other Park anc Fide re- quires a c;ncitioral use permit. (Ord. 3690, 8-4.86, Sec:icn S. Commercial parking facilities are limited to spaces in surface Icts whic') are not requiret pursuart t0 SeCJOn 20.25A.050. Commercial lots must CCmpiy with the requirements Of Paragra.^dh 20.25A.0!0.0. (Ore. 3747, 1 20 0; , Sec:ien i) �. 9. Accessory parking'ecuires apcfcva! thrcucn the fEview pf ,CEgg rE^UirE�', for th ^ which i E cnc U_2 C. t Serves pursuant to ScCaOn 20.10.!40. (Crc. 374,', 1.20-07, Sec:loll 1) 1111 10. Onsite hazardous wase treatment and storace facilities as defined t;v 20.50.02a are oniv permitted as administrative conditiona use acorovals as a subordinate use mitted oso (hese fac r ecia use. i i i must COmDiv wttn the to a perMate sl ti no Criteria as adopted In aCCOr�dnCeewith C.4 0.105.21:. I1. Offsite hazardous waste treatment and storace facilities as defined by 20._ 1.02a ,must comolY with the Sc a_e siting criteria as aeo�tec i accordance with �0.:05n. 10. 1W 17 L 1 B-14 so I M 1 ! 1 i 1 1 1 1 1 1 1 1 1 i 1 1 1 Section 2. Bellevue City Code (Land Use Code) 20.50.024 is amended Nan Campbell, Mayor Approved as to form: Richard L. Andrews, City Attorney Assistant City Attorney Attest Maria K. O'Connell, City Clerk Published by the addition of the following definitions. HAZARDOUS WASTE. All dangerous and extremely hazardous waste as defiled in R(11 70.105.010 except for moderate—risk waste. HAZARDOUS WASTE TREATMENT AND STORAGE FACILITY, ONSITE. These are facilities which treat or store wastes generated on the same site. HAZARDOUS WASTE TREATMENT AND STORAGE FACILITY, OFFSITE. These are facilities which treat or store wastes generated on properties other than those on which the facility is located. HAZAROCUS WASTE STORAGE. The holding of dangerous waste for a Lit temporary period as regulated by State Dangerous Waste Regulations, Chapter 173-303 WAC. HAZARDOUS WASTE TREATMENT. The physical, chemical, or biological processing of Jangerous waste to make waiter nondangerous or leis dangerous, safer for transport, amenable for energy or material resource recovery, amenable for storage, or reduced in volume Section 3. This ordinance shall take effect and be in force five days after its passage and legal publication. PASSED by the City Council this day of 1987, and signed in authentication of its passage this day of 1988. (SEAL) Nan Campbell, Mayor Approved as to form: Richard L. Andrews, City Attorney Assistant City Attorney Attest Maria K. O'Connell, City Clerk Published ` 70'^^ aw /991 `wn /*a /mx 1995 /nm /99/ /mm /em 2000 mm/ RESPONSIBLE AGENCY ^^^^^^^^^^^^=```==============='~^~====^`===`=`=======`===============`'=```===``=`=~==`=========`====``======`===`=`=`== HHV EDUCATION COMPONENT ^m,om/ngmunh PUmu INFORMATION ANO OUTREACH Staff // Fm 40,000 140,000 $40.000 ^m.mm 140.000 $40.000 $40.000 140.000 llo.mm 140.000 $40.000 140.000 ww/*supp/.w 10,000 m.mm 10,000 10,000 m.mm 10,000 10,000 10,000 10,000 10,000 10,000 10,000 oan°"/ Promotion and Publicity media publicity 5.000 20.000 20.000 20.000 20.000 20.000 5.000 5.000 5.000 5.000 5.000 5.000 Ewmuv*moc involvement activities 25,000 50,000 /5.000 /o.wm 200,000 200,000 50,000 m.mm 50.000 m.mm 50,000 50,000 p,wenmumns 20,000 25,000 25,000 25,000 25,000 25,000 m.mm 25,000 25,000 26,000 25.000 m.mm Ne^"a*,u^ m"m Reduction owwuw aoo (/ no 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40.000 40,000 40,000 40,000 40,000 wwm/suppo~ 10,000 10,000 10,000 10,000 10.000 10,000 10.000 10,000 10,000 10.000 10,000 10,000 Waste reduction mm/mvu".*i; 50,000 $0,000 50,000 /00.000 /m.mm /50.000 200,000 200.000 200.000 200,000 200,000 200.000 *vta reduction programs 50.000 100.000 /50.000 250.000 300.000 300.000 300.000 300.000 300.000 300.000 300.000 300.000 *ww mHW n.FPHoNE INFORMATION LINE Sm// //'3 Fm 40,000 60.000 80.000 $0,000 100,000 /m.mm 120.000 /20.000 .m.mm 120.000 /m.mm |m.mm m^'n/suwow 10,000 /5.000 20,000 20,000 25,000 30,000 30,000 30,000 30,000 30,000 30,000 30.000 ''ng C('Un* mHOwmOGRAx ouv // nn 40,000 40,000 1111,000 40,000 40.000 10.000 40,000 40,000 40,000 40.000 40,000 40,000 *w."/supp/.w 20,000 20,000 20,000 20,000 20,000 10,000 10,000 10,000 10.000 10,000 10,000 10,000 u^ncuw development 40,000 35,000 25,000 10,000 5.000 5.000 5.000 5.000 5,000 5.000 5.000 5.000 m"ungm*mwtm" 30,000 30,000 20.000 10,000 5.000 5.000 5.000 S.mm 5.000 6.000 5.000 5.000 leacher training // no o 40,000 40,000 40,000 40,000 20,000 10.000 10,000 10,000 10.000 10.000 5.000 Workshop presentations |/ nu 110,000 40,000 40,000 w= 40,000 40,000 40,000 40,000 40,000 10,000 40,000 40,000 *6c=«/ prmvmw // Fm ^ 40,000 40,000 40,000 40,000 40,000 40,000 40.000 40,000 40,000 40,000 40.000 /'^,"v6upp/'w 5.000 10,000 10.000 10,000 10,000 10.000 10,000 10,000 10,000 10.000 10,000 10,000 *wlth ADmwmRAnON *HW Education program pmmnaur |/.o no 45,000 45,000 45.000 45,000 45,000 45,000 45.000 45,000 45,000 45,000 45,000 45.000 /dpm/supp^m �������� �-_���_�������������_-----------------------------------------------------_�������'�����������������_�����_�------- 11,250 11,250 n.»m n.,m 11,250 11.250 11.2m 11,250 11,250 o.nm 11,250 11.250 ...,`..=,,.`.==-.===.,`,,=`==.`============.,``=`=.==='==,==.`===,```=====,``=,=`===`==.=.==,.,,=`==,,.``=========, pw[DuznO%mwm^*/ mnu 153/.250 1731.250 1811.250 $166,750 11,116,250 11.171.250 11.041,250 o/.mm.om $1,046,250 m.*m.xm 111.045.2w u.w/./m Ir iv. Ny 5 W @8 I I N I I 1 1 , "o oo 2002 mm mw mwo 2006 nmr 2000 amoTWENTY YEAR CUMULATIVE RFIPONSmLE AGENCY nHW EDUCATION COMPONENT wvo/^ng County mmn INFORMATION AND OUTREACH Staff oFv| 140.000 140.000 640.000 140.000 $40.000 140.000 $40.000 $0.000 *w.*suw/`w 10,000 10,000 10.000 10,000 10,000 w.mw 10,000 *.mm General Promotion and Publicity Media publicity 5.000 6.000 5.000 S.000 5.000 5.000 5.000 5.000 Enmu/*moc wVo/*"entwu.,/uw 50.000 $0.000 $0,000 $0.000 $0.000 $0.000 50.000 50,000 ',"senmnons 25,000 25,000 25.000 25.000 25.000 26.000 25.000 25.000 Ne',.'sww^ Waste Reduction Promotion o*/' i/ no 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 w^/*suppow 10,000 10.000 10,000 10,000 10,000 m.mm 10,000 10,000 waste reduction mm/m^u,/o/i; 200,000 200.000 200,000 200,000 200,000 200.000 200,000 200,000 =mreduction progress 300.000 100.000 300.000 300.000 300.000 300.000 300.000 300.000 °w/m mHW numoe INFORMATION LINE Staff //'3 no /m.mm /m.mm /m.mm /m.mm /m.mw /m.mm /m.mw /m.mm Adm.wtuppom 30.000 30,000 30,000 30,000 30,000 30,000 30,000 30,000 ''"vcc'=w SCHOOl. PRowwo m^/f // no 40,000 40.000 40,000 40,000 40,000 40,000 40.000 40,000 Admin/supplies 10,000 10.000 10,000 w`mm 10.000 10,000 10,000 10,000 Curricula development 5.000 5.000 5.000 5.000 5.000 5.000 5.000 5.000 »mumvm^tr'buuon 5.000 5.000 5.000 5.000 5.000 5.000 5.000 5.000 /wm* training o nu 5.000 5.000 5.000 5.000 5.000 5.000 5.000 5,000 workshop pmwtauw* |/ «o 40,000 40,000 40,000 40,000 40,000 40,000 mwm 40,000 In -school programs // no 40,000 40,000 40,000 40.000 40.000 40,000 40,000 40,000 /,x*Vsuppxw .o.mm 10.000 10,000 10,000 10,000 10,000 10,000 10,000 *w/th ADwmow/mw *wEducation program coordinator |`.v Fm 45.000 45,000 45,000 45,000 45,000 45.000 45,000 45,000 Admin/supplies .`.250 11,250 11,250 o.,m 11,250 11,250 --------------'-----'---------' 11,250 11.250 ''--- ------ -------------- ------------------------- wwEmmnONmMPoNE"/ TOTAL ---- -------------------------------------------------------------------------------- p.04/.250 m.w`.,m w.w`.cw m.m`.om $1,041,250 m.w/.om u.w/.mm m.m\nm $20,010,000 1990/s/ 19921913/mw 1995 loss 1997 /em 1999 2000 NOT NNW COLLECTION COMPONENT uwnw/mtro PERMANENT mnunEo uw'w costs / 3 ^ 6 o v o v o o o o Planning and administration 20,000 20,000 20,000 m.mm o v o o o o « » Site design and prop 20,000 20,000 20,000 20,000 o o o o o v o o NNW storage structure 50.000 50,000 $0.000 50.000 v o o o o o o o EQu'pment /m*ps, fences, w'u. wu| 5.000 5.000 5.000 5.000 o o o o o ^ ^ o Permits /.mm /.mm 1.000 /.mw o o ^ o o v o o /mm.ng 10,000 10,000 10,000 10,000 v o ^ o o v o o Total ^xm.mm 1105.000 6106,000 w06.000 w m so so so to w to Operating Costs Staff 132,600 19/.150 /m.wm 306.000 136,600 352.120 426.400 ^`wm 420.400 420,400 489,000 m/.ww m"m/Supoow o./m ^/.wm 48.620 /o.mw w./w 88,230 m/.xm 103,530 /m.xm 10/./00 122.400 145.350 016D061/ wa.m/ wo.^m wo.'m /.m,.mv /.wu.ow /.eo.mw ,.nw.ww 2.755.409 3.235.591 x./w.mm 4,173.561 4.315.151 wm/ muo.a/ wmuw 11.011.5591/.*40.31612.043.714 m.uo./m 12,923,914 13.213.059 p.,n.m/ 14.211.032 w./85.60/ 65,042,209 PERMANENT FACILITIES TOTAL mm ;735.25/ 1991,1/6 w.n/.ymw.mo.uom.mon $2.353./94 12,923,964 13.213.059 13.17/.091 $4,719,032 14.185.56/ v5.042.209 ling Cow* wmxF /ACmna capital costs Collection m,ucux" 25.000 25,000 o o o o o o v o o o mn�, /wm~» 4.300 4.300 o ^ o o o ^ « « » » Permits /.mm /.mm o o , o o o o o o o Equipment 3.000 3.000 o o o o o o o o o o ww/ 133,300 133.300 10 10 so so to $0 so so w so Operating Costs Staff 68.000 136.000 204.000 204.000 204.000 204.000 204.000 201.000 204.000 204.000 204.000 204.000 wain/Supplies 17,000 34,000 51,000 51.000 51,000 $1,000 o/.mm 51,000 51.000 51,000 $1,000 51,000 »"m lease 5.000 10,000 15,000 /S.mm 15,000 /5.000 15,000 15.000 15,000 15,000 15,000 m.m* Set up |6 / nw,> 7,200 14,400 21,600 21,600 21,500 21,600 21,600 21,600 21,500 21,800 21,600 *.wm Disposal 234.000 468.000 70,.000 102.000 702.000 702.000 102.000 102.000 102.000 702.000 702.000 702.000 Total $o/.nm v55/.400 1993.400 $993.600 $993.e0 1993.800 1993.600 1993,100 $993.500 1993.600 1993.600 $993.600 mmx; FACILITIES mmx 1354.500 6695./00 w93.800 6993.600 $993,500 1993.600 1993.100 m93.600 w93.600 6993.500 1993.600 $993,600 m/m FACILITIES COSTS u.mw.a/ $1.586,816 12.191,15912.539.91013.03/.314 13.386./94 w.m/.y" w.nm.^m w.154.69/ 15.272.532 15.179.26/ $5.035.809 w=m^/w"o County PROMOTION OF oxnmw "ACmxe 25,000 25,000 /5.000 25,000 25,000 /.mm 25.000 /.mw /.mm ,.wm 25,000 /.mm uwu*/m"vCom4 TARGETED WASTE uuLm/mwREou/kG waste oil mnmuon 50,000 50.000 50,000 /00.000 100.000 100,000 100,000 100,000 /00.000 100.000 100,000 100,000 Recycling pilot projects $0,000 50,000 50,000 $0,000 o o o o o o o o Program implementation o 25.000 50.000 50.000 50.000 100.000 100.000 100.000 /00.000 100.000 /00.000 100.000 f/^t^^IOil points, so/°wmi umwnRA/xm umuw ~w Collection program coordinator 10.5 FIE) 22, 500 22,500 22.500 22,500 22,500 22,500 22,500 ,,.om 22,500 22,500 22,500 22,500 sing County mmCoxmuon program coordinator m.5 Fm 22,500 22,500 22,500 22,500 22,500 22,500 22,500 22,500 22,500 /,.mm 22,500 22,500 --- '-----------------------'-------------------------------'-----'---------'-------------'------------- w^m/6uwoes 11.250 11.250 11,250 11.250 11.250 11.250 11.250 11.250 11,250 11,250 11,250 11,250 mm COLLECTION COMPONENT mm/ m.w\ow x/.em./m $2,422,409 ;x m\,m 13,268,624 m emwu � /�m^ w�mmmm Wm/ m` $5,535.112 �mm m/ ��ommm -----'-----.----_—_—_----------_---------_--'---�------'---'�—'�__'�—'�_---'�---'�—'�---'—'-----�'—�------�-- w~nm wm/ w.w,.a/ m.w*.no w.233.55963.80/.418w.444.874 64.82/.254 w.245.014 15.576./51 11.on.m/ w.mm./o m.xw.m/ m.mw.om00 ~^ IL—� �� L� L—^ L—.... L- I I 1 N[ 9- 9 9[ F I @K //m/m 200/ mm 2004 2005 2005 2007 2008 2009 TWENTY YEAR CUMULATIVE NNW COLLECTION COMPONENT mwuw*mm PFRNmEwrACm/oo Capital Costs ^ ^ o o o » o o Planning and wmm/mmtvp o o o o o o o v Site design and prop o o o o o o o o WNW storage structure o o o o o o v v aw.pmwt(m*og. fences, carts, etc) v o o o o o o o Permits o o o o o o o o owm`ng o o o o v o o o Total w m to to so so 10 so Operating Costs ouo *2.000 612,000 612.000 012.000 612,000 612,000 112,000 m/.mm mm.r/Supp^w 153,000 /m.mm /u.mw /o.mm /m.mm /o.mm `m.mm /o.mm Disposal ^.um.m/ ^.mm.mm ^.nm.wo ^.m/.w/ 5.100.22/ 5.2/5.895 5.453.860 5,643,306 Total w.225.10/ w.n^.mn 15.533.982 15.596.441 ^5.805.22/ 16.040.695 16.218.860 16.408.304 nRNAN(m"mm/oSTOTAL COST 15.725.70' 65.374.952 15,533,982 m.mm.w/ v».ma.on $5.040.895 $5.218.860 $8.408.306 King County mmxE"mumm m,`m/mst* Collection structure o o o o o o o v wm^, fencing o » » « « » » » ,erw/m o o o o o o o » Equipment ^ » » » » » » « Total so w m 10 $0 so so so operating Costs vm* 204.000 204.000 204.000 204.000 204.000 204.000 204.000 204.000 w"m/Suwxes 51,000 $1,000 51,000 51,000 51,000 51,000 51,000 51,000 Truck Tests 15.000 15.000 15,000 15.000 /5.000 15,000 15,000 15,000 yu ~ m x year) 21,600 21,500 21,600 21,400 21,00 21,600 21,400 21,600 o.SP061/ 102.000 10/MO 702.000 102.000 102.000 702.000 102.000 702.000 Total ^n^mm ,vm.wm ^993.500 1193,500 $993.600 $993,600 $993,600 1913.600 mmxE FACILITIES COSTS 1993.500 v*«.mm 1993,500 1993.500 1993,600 $993,600 $993,500 $993.600 TOTAL FACILITIES COSTS 16.219.30/ 16.358.56/ w.o/.m, $8.590.041 vo.mo.m/ $1,034,495 17.212.450 m.w/.mm mwmw"ng County PROMOTION OF uuaoxm"mu,no /.mm /.mm ,.mm /.mm /.mm /.mm /.mm /.mm ywu/wwmlmunty FATIGUED VAST[ muonmwRIoc/NG w^st*m/ womow /00.000 100,000 100.000 100.000 /w.mm /00.000 /00.000 /00.000 Recycling pilot projects o o o ^ o o o o Program implementation 100,000 100,000 /00.000 /00.000 /00.000 /00.000 100,000 /00.000 |/^u*Ioil po.mv.sol*mo) mmmmnm/xm uwuw *HV Collection program coordinator (0.5 FIE) 27,500 22,500 n.ym 22,500 22,500 22.500 22,500 22,500 King mwty mm Collection program cwmmvov 10.5 Fm 22.500 22,500 22,500 ,/.ym 22,500 22,500 22,500 22,500 Amin/supplies ".rm ------------------------------------ n.250 11.250 11,250 ------------------------------------------------------ 11,250 x./m ./.cm ----------------------- n.nm --------------- -------------- ---...... ------------------------------------- mmCOLLECTION COMPONENT mm 16,462.551 11.631.812 w./m.m, m.yo.m/ w.o,.m/ $1.2ST./45 N.uo./m m.mm./561103.40/.134 ����������������������������_�����- mwnANmuL ---------- 11,523.80/ -------------------------------------_��'�����������������_���������������������_ x/.513.062 m.00.mo V/.ew.m, 18.153.321 16.338.995 $8.511.960 11.106.406 Nn.w/.rw w . 1/20,89 1990 1991 1992 1993 1994 1995 1995 1991 1998 1999 2000 2001 SOG EDUCATION COMPONENT Nitro INFORMATION DEVELOPMENT AND RESOURCES Education materials development Staff (0.5 FIE) 10,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 10,000 20,000 20,000 NeW61itter, brochures, dist/div. 15,000 15,000 15,000 15,000 15,000 15,000 15,000 15,000 15,000 15,000 15,000 15,000 Seminars and workshops Staff 11.01 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 Admin/supplles 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Resource Library Staff 11.0 FIE) 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 Admin/suppl1e6 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Materiels and data acquisition 10,000 20,000 20,000 24,000 24,000 24,000 24,000 24,000 24,000 24,000 24,000 24,000 Computer system 15,000 5,000 5,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 „filth IEIEPHONE INFORMATION LINE Staff (I - 2 FTE) 40,000 40,000 80,000 80,000 80,000 60,000 80,000 80,000 60,000 80,000 80,000 80,000 Admin/supplies 10,000 10,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 Rent/01101146/116c 2,000 2,000 4,000 4,000 84,000 84,000 84,000 14,000 84,000 84,000 84,000 84,000 Health PASSIVE WASTE EXCHANGE Staff 11.5 FIE) $1,000 $6,500 56,500 56,500 56,500 56,500 S6,S00 $8,500 $8,500 56,500 58,500 56,500 Admin/supplies 13,000 13,000 13,000 13,000 13,000 13,000 13,000 13,000 13,000 13,000 13,000 13,000 Phones/vehicle/mist 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 Printing 20,000 20,000 10,000 20,000 20,000 20,000 I0,000 20,000 20,000 20,000 20,000 20,000 Nitro TECHNICAL ASSISTANCE PROGRAMS Waste reduction, recycling and treatment Staff 11 0 if[) 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 Admin/supplie6 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Needs 16686631ent 10,000 20,000 20,000 20,000 20,000 0 0 0 0 0 0 0 Waste stress analyses 20,000 20,000 30,000 30,000 30,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 Newsletter and technology transfer 0 60,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 incentives/sward6 program 20,000 50,000 $0,000 50,000 50,000 50,000 60,000 60,000 60,000 60,000 50,000 60,000 On-site consultation Coordinator (1.0 FIE) 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 Field staff (1-4 FTE) 80,000 120,000 160,000 180,000 160,000 150,000 150,000 160,000 150,000 160,000 160,000 160,000 Admin/supplies 30,000 52,006 52,000 52,000 52,000 51,000 51,000 52,000 $2,000 51,000 52,000 52,000 Vehicles/tran6portation 20,000 23,000 4,500 4,500 4,500 4,500 4,500 4,500 4,500 4,500 4,500 4,500 Waste characterization and treatment Staff (planning and management 1.0 FIE) 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 Stiff (operations and analysis 1-2 FIE) 0 45,000 90,000 90,000 90,000 90,000 90,000 90,000 90,000 90,D00 90,000 90,000 Equipment 0 150,000 90,000 90,000 50,000 50,000 20,000 20,000 20,000 20,000 20,000 10,000 Lab analysis 0 40,000 100,000 100,000 100,000 100,000 100,000 100,000 100,000 100,000 100,000 100,000 Admin/6up01146 20,000 22,500 60,000 80,000 60,000 60,000 60,000 60,000 60,000 60,000 80,000 80,000 Nitro ADMINISTRATION SOG Education coordinator 11.0 FTFI 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 45,000 ------- Aon n/supplies •--- ------------------------------------------------------------------------------------------------------------------------•--•---------------------------------------------------------------------- 11,250 11,250 11,250 11,250 11,250 11,250 11,250 11,250 11,250 Ii,250 11,250 11,250 SOG EDUCATION COMPONENT TOTAL 8158,250 81,160,250 81,311,250 61,311,250 61,211,250 61,236,250 61,106,250 81,206,250 81,206,250 61,200.250 81,206,150 61,206,250 M M M M M M M M M M W M BOWA I N & N I 8 8 Iwo � IWO I I A I U 1/20/19 2002 2003 2004 mm 2005 2001 2008 2001 TWENTY YEAR CUMULATIVE msEDUCATION COMPONENT vetw INFORMATION DEVELOPMENT AND RESOURCES [mxm'onmaterials de*/op"in' Stiff 10 5 nn 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 Newsletter, brochures, *stm*, /5.000 /5.000 75.000 /5.000 /5.000 75,000 15,000 15,000 Seminars and workshops m^o /w| 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 ww'"/supp»m 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 Resource Library Staff /'.« nu 40,000 40,000 40.000 40,000 40,000 40.000 40,000 40,000 mw'"/typli//w 10,000 10,000 10,000 10.000 10,000 10,000 10,000 10,000 Ma,*'«* and do acilv'^'t'on ,*,mm *.mm 24,000 24.000 24.000 24,000 24,000 24,000 mmp"ur o,^m^ /,mw /.mm /.mm /.mm /.mm /.mm /.mm /.mm ww/w oamo* INFORMATION LINE smo // r ew 80 '000 80,000 so '000 so '000 go '000 80.000 80 .000 80 .000 Aw'wsuwow m,mm 20,000 20,000 20,000 20,000 20,000 20,000 20,000 venuphorw/n/sc `^,mm w.oCo v^.mm 14,000 $4,000 ^^.mm $4,000 64,000 *w/m PASSIVE WASTE nmANo Stiff //.5 no so '500 56,500 so '500 56 '500 56,500 55, Soo 55, Soo 55,500 w,m/suppow 13,000 .3.000 13,000 13.000 13,000 13,000 13,000 13,000 Ph~oo/°*.u*".m 5.000 5.000 5.000 5.000 5.000 5.000 5.000 5.000 w."unj mmm 20 000 20,000 20 000 20,000 20,000 20 .000 20,000 114"" /(n~/m ^omANm PROGRAKII lasts reduction, recycling and treatment o^o 1' u xn 40,000 40,000 40.000 40.000 40,000 40,000 40,000 40,000 wo.u/oupp'.w 10,000 10,000 10.000 10,000 10,000 10,000 10,000 10,000 Woods ^ww~wt o o o o o o o o Wa=te^umse analyses 5.000 5.000 5.000 S.mm 5.000 5.000 5.000 5.000 ww*/etu, and mmno/og/ transfer 45 '000 45 .000 45.000 45 000 45,000 45 .000 45 '000 45 '000 /nconu,^ww*ds prol,as 60 'mm 60 .000 50.000 60 '000 $0.000 50 '000 60 .000 60 '000 On=tsorm/muon mwmnao, |`.o /m *o.mw 40.000 40,000 40,000 40.000 40.000 40.000 40,000 /',w m"x |/'^ no 160 '000 160 '000 150 '000 160 '000 160.000 160 .000 /60.000 /60.000 wu."/jullpxw $2.000 52,000 52.000 52,000 52,000 52,000 52,000 s.mw vw.uwvuwipv mow ^,mo ^.um ^.ym ^.ym ^.om ^.ym ^.ym ^,ym Waste characterization end trmtmen, o^o mwnn.ngand w=w"ent /.ono 45.000 45,000 45,000 45,000 45,000 45,000 umm 45,000 o"o /oow^uon" end *w//v.^ /-/ nn 90 'mm so .000 90 000 90 .000 90.000 90 '000 90 .000 90 .000 Iqu.ppont 20,000 20 '000 m.^00 20 .000 20 000 20.000 20.000 20,000 tab ww/rw" /00,000 100.000 /00.000 /00.000 /00.000 /00.000 100,000 /m.mm w"m/juppxos 50 '000 50.000 50 '000 60 '000 60,000 60 '000 60 '000 so .000 Metro ADMINISTRATION nw Education om'o/nam' no on 45.000 m.m* 45.000 45,000 45,000 45,000 45,000 45.000 w".*suppow 11.2m 11.250 n.,m 11.250 11,250 11,250 11.250 11,250 ----------------------------- -------------------------------------- mnEDUCATION COMPONENT /mw ---- '' --- m.nw.,m --------------------'--'------------------------------------- w.om.om 11,206,250 $1.205,250 11.206.250 11.205.150 w.206.250 $1,200,250 $23,936,000 '',o/m /aw /s/ /992 /em /yu `em /mm 199/ /em /rm 2000 om/ ^^^^`^^^^'==~'=====^=======`==`=`='=`========='``===^=`''=`=====```========'===========``=='===========``=```==`=========`= wmCOLLECTION COMPONENT King County mmuF Fmumo (2 total, 1990 and /nm| m^o (p/mts 'ndwu/) $105,000 w05.000 pm.mm 1210,000 1210,000 $105,000 $105,000 so 10 so so to /,muv w year /ww| 100,000 o 100.000 o o o o o o o o o E=P11611t. Was, fencing 10,000 10,000 20,000 10,000 10,000 5.000 5.000 v o o v o Se** costs 5.000 5.000 10,000 10,000 10,000 5.000 5.000 o o o o o Planning and training 25.000 25.000 25.000 10.000 4.000 4.000 4.000 o o v o o King County AUXILIARY FACILITIES (IINmmMD/993) Sm// |w/vim industry) o `m.mm 105,000 210,000 210,000 210.000 105,000 105,000 o v o o Sheds and storage units o 30,000 o 30,000 o o v o o o o o Site design and preparation o 20,000 o 20,000 o o v o o o o o Equipment and permits o 10.000 5.000 10,000 10,000 10,000 5,000 5.000 o v o o »*/o.mVo/m^'ng/amm o /5.000 10,000 25,000 10,000 10,000 10,000 10,000 o o o ^ King County 251SUBSIDY or swmSPoaL uon v 1143,000 1218,000 $297,000 1380.000 ^uo.mm so so so so so to Consultant costs (program setup) 40,000 (251 of waste collected and recycled or disposed) PROMOTION OF ox/w/mw SEwxzo Staff 10.5 FTE) ^m.mm 120.000 $20,000 $20,000 ^m.mm $20.000 120,000 620,000 so to so w Wr/^/om'**`buuon 20.000 20,000 20,000 20,000 20,000 20,000 20.000 20,000 o o o o king County ADMINISTRATION mmCollection coordinator (I FIE) 45,000 45,000 45,000 45.000 45.000 45,000 45,000 a.mw o o v o ---- ----' Admin/supplies ----- ----- '------------------------------------------------------------------- 11,250 11,250 11,250 11,250 11.250 11,250 11.250 11.250 o o o o ywCOLLECTION COMPONENT TOTAL vm/.xm 115/11,250 ----------- ^/a.xm ------------ 1926.250 --------------------- 1940.250 ^a/.om ---------- ^uu.ow --- -------------------------- $216,250 w so '-'----'---'---'--- w $0 W t r r I F t � F F F F I 1 1 1/20169 2002 2003 2004 2005 2006 2007 2008 2009 TWENTY YEAR CUMULATIVE SQG COLLECTION COMPONENT lint County MOIRE FACILITIES 12 total, 1990 Slid 11921 Staff (private industry) to to 10 $0 $0 so $0 so Trucks IS year Ismael 0 0 0 0 0 0 0 0 [quipaillit, berms, fencing 0 0 0 0 0 0 0 0 Setup costs 0 0 0 0 0 0 0 0 Planning and training 0 0 0 0 0 0 0 0 King County AUXILIARY FACILITIES (I IN 1991 AND 1993) Staff (privets industry) 0 0 0 0 0 0 0 0 Sheds and storage volts 0 0 0 0 0 0 0 0 Site design and preparation 0 0 0 0 0 0 0 0 Equipment and permits 0 0 0 0 0 0 0 0 iraininglplseningladain 0 0 0 0 0 0 0 0 king County 251 SUISIDY of SQG DISP06AL COSTS so 10 so to so $0 $0 60 Consultant costs (program setup) (261 of waste collected and recycled or disposed) PROMOTION OF COIL(CIION SERVICES Staff (0.5 FTEI so to $0 $0 so $0 $0 so Materials/distribution 0 0 0 0 0 0 0 0 lint county ADMINISTRATION SQG Collection coordinator IT FTE) 0 0 0 0 0 0 0 0 Aloin/supplies 0 ------ 0 ----------------------------------------------------------------------------------------------------------------------------- 0 0 0 0 0 0 ----------- ------- --- ------- ------ ------------------------------------------ -- - - ------ $00 COLLECTION COMPONENT TOTAL -- -- -- to to so $0 $0 so to 10 15,166,000 W /'m'w /mm /s/ /ya /eo /+m /ea /mw 199/ /mm /mw 2000 mm/ om COMPLIANCE COMPONENT Regulatory Agencies REGULATION CHANGES AND ENHANCEMENT ms Staff N./Fn/itioncy} $40.000 $40.000 120.000 120.000 $20.000 65.000 15,000 $5,000 $5.000 15.000 $5.000 $5.000 w"/*6Uwow 10,000 10,000 5.000 5.000 5.000 1.250 /.ow /.ow /.250 \om /.nm \om Enhancement of /wm/ ormw^w: Stiff 10.1 FTI/agency) 40,000 40,000 20.000 20,000 20,000 o o v o v o o mm/n/6uppow 10,000 10,000 5.000 5.000 5.000 o o o o o o o Metro mw COMPLIANCE wnpo"w o^um,k xmr/ (/ 2nE) 40,000 80.000 $0.000 60.000 80,000 80.000 80.000 $0.000 80.000 80.000 80.000 80.000 Adm/"/^uppow 10.000 20.000 20.000 20.000 20.000 20.000 20.000 20.000 20.000 20.000 20.000 20.000 nm/umvmw'pment 20,000 /.um /.am /.am /.sm /.ym /.ym \um /.ow /.om 1.500 /.mm /w*/ng for participating agencies 19,200 19,200 m.m* 11,200 19,200 15,200 11,200 19,200 19.200 19,200 19,200 19,200 »upp/'w, mm 20.000 20.000 20.000 20.000 20,000 20.000 20.000 20,000 20.000 20.000 20.000 20.000 mns"/upt 50.000 o o ^ o o o o o o o o mupuur orvm" 25.000 ,.mm ,.mw 2.000 2.000 2.000 2,000 2,000 2,000 2.000 2,000 2.000 Metro Response network follow-up inspections Stiff (1-4 FIE) 40,000 80.000 /m.mm /60.000 /50.000 /50.000 `6o.000 .w.mw 160.000 /w.mw /60,000 160.000 veh/um/w*/pm~n 20,000 3.000 23,000 6,000 6,000 5,000 6,000 6,000 6.000 ^.mm 5,000 ^.mm *w.o/wppxm 10,000 20,000 30.000 40.000 40,000 40.000 40,000 40,000 40,000 40.000 40,000 40,000 .*m y^.o,^ Staff 11-5 FIE) 40,000 80.000 /m.mm /w.mm 200,000 240,000 240,000 240,000 240,000 ,w.mm 240,000 »m.wm mdmm/soppow 10,000 20,000 30,000 40,000 50,000 50.000 50.000 60.000 60.000 60.000 60.000 60.000 weh/c/m/ww/w=t 20,000 /.om 23,000 4.500 21,000 /.yw 9.000 9,000 9,000 9,000 1.000 9,000 w*/w Audits a^x (3-12 FIE) /m.mm /60.000 200,000 m^.mm 280,000 320.000 310.000 400,000 440,000 wo.*m 460.000 480,000 Admm/6UPPx011 30.000 40,000 50,000 60.000 10,000 80.000 90.000 /00.000 110,000 tm.mm /m.mm /m.wm vshsw^/w*=t 20,000 24,500 ^.mm 21.500 9.000 30,500 12,000 33,500 15,000 35,000 18,000 18,000 wt,^ mmmm/RAnw mQG Compliance coordinator It Fm 45,000 45.000 45,000 45,000 45,000 45.000 45,000 45,000 45,000 45,000 45.000 45,000 --- ----------------------------------------- ^dm'"/supp//ai; -------------------- ---------------------------------------------------------------- 11.250 11,250 11,250 11,250 11,250 11,250 11,250 11,250 11.250 11,250 11,250 n./w mmmmL|ANm mwmNEm TOTAL ������----------- ----- ----------------------------------------------------------------'�������������������������������­ 1e50.450 1127.950 $850.950 1906,950 11,089,950 ----'-----------------------------'-'----'---' ^Vw.om m./m.mm 11,253,100 11.285.200 11.355.200 t/.zw.om v/.zm.om mmnAN mw w./89.950 12.462.450 12.90/.45013.225.45013.30/.450 13,316,100 m'/o.xm 12.016.200 12.491.450 n.511.450 ----------------------- 12.544.450 12.544.450 �� 91--A �� L.-,4 9Ab,.__ L - L_�A B"ima L� t_ �_ - L &A- L --- L_ - C_ 4 L-4 LW L ee�. xm/w 2007 2003 2004 2005 2006 2007 2008 2009 TWENTY YEAR CUMULATIVE mmmMPLmNCE COMPONENT .===,=,==,`==,,=`=====,=========,,=========,,===================`,`======== RelvwxvrAl"wwo NEom^/xmCMmmxANO ENHANCEMENT |mu Stiff {mFn/eloncv| 15,000 x5.000 $5.000 15.000 $5.000 15.000 $5,000 65,000 ww'*lopp»ss /./m /.om /.om /.ow /.om \om 1.250 /.am [mwncemwtm l*m/ ordinances Staff (0./Fm/awnc,) o o o o o v v o wm/wsupo)/= o v o o v o o o metro nwmMPLmNCE Response flew~x Staff (/'IFIE) 60,000 80.000 80.000 60.000 60.000 80.000 80,000 80`000 *m'"/suw»w 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 Vehicles/equipment ..ym /.ym `.ym /.ym '.ym /.mm /.ym /.ym »w^`nj nrwvt.ppaonj elwcw^ /v.xw 11,200 19,200 19,200 19,200 19,200 11,200 19,200 Suwl'es, mm 20,000 20,000 20,000 20,000 20,000 20,000 20,000 20,000 Consultant o o o o o o o o Computer system 2.000 /.000 2,000 2,000 2.000 2.000 2.000 2.000 uetm Response network follow-up inspections omo 11-4 FYI) /50.000 /40.000 /60.000 /50.000 /60.000 /60.000 /80.000 160.000 w*/umup*`psm"t ^.mm 5,000 6,000 5,000 6,000 5,000 6.000 6,000 w".o/oupp»w 40,000 40,000 40,000 40,000 40,000 40,000 40,000 40,000 wuv ar,n" mmo |/-^ nH 'w.mm 240,000 240,000 240,000 240,000 240,000 240,000 240,000 w^w/suppl.w 40,000 60.000 60.000 50.000 60.000 60.000 60.000 10,000 9.000 9,000 9,000 1.000 9,000 9,000 9,000 9,000 ww/m wm'm Sm// 13-12 FIE) 480.000 ^oo.mm 480.000 480,000 400.000 480,000 480,000 480.000 wo/www"ag 120.000 `m.mm /m.mm /m.mw 120.000 `m.mm /m.mm /m.mm w*mwwo `pe^"t 18,000 18,000 11,000 18,000 18,000 18,000 m.mm 18,000 wm* mwwom*xm mmCompliance coordinator " FIE) 45,000 45.000 45.000 ^».mm 45,000 45,000 w.mm w.m* ---_---__--_.---_--_-.-.--'---------.------.---------------------'-'-_----------'-------_'-'--_-----------'-----'- mm/*suppl`w v./m 11.250 11,250 11,250 11,250 11.250 11,250 11,250 --------- ---------------------------------------------------------------------------------------------- mwCOMPLIANCE COMPONENT TOTAL 11.131.200 w.338.200 $1.338,200 11,338,200 11.338.200 11.3311,200 $1,338,200 11,338,200 $n.00./w wQGPLAN TOTAL w.u^.^m w.w^.wm ---------------------- 12.aw.450 ---'--------'----------------'---_---'---------- m.w*.om p.u^.^w $2.544.450 m.544.450 m.w*.ww 153.015.750 1! 201,89 /so 1991 199/ wm /rm mw 1996 xmr /em /mm 2000 2001 PROGRAM Enuw/xmmxmmm xs»oW»cmlLEMsnm Evaluation Coordinator |/ FIE` m.mm 45,000 45,000 a.mm 45,000 45,000 45.000 45,000 45,000 45.000 45,000 ^S.mm mHW Education ww/usuwmpd^m `:.mm 20,000 10,000 10,000 20,000 10,000 10,000 10.000 10,000 10,000 5.000 S.mm mw Collection *wluauw/updam 13,600 10,000 5.000 5.000 20.000 2.000 2.000 2.000 2.000 2.000 2.000 ,.mm om Education *wluauon/tiodam 34,000 20,000 5.000 5.000 20,000 2,000 ,.mm 2.000 ,.mm 2.000 ,.mw 2,000 om Collection evaluation/update 20,400 10,000 3.000 3.000 10,000 2.000 2.000 2.000 o o o o sm Compliance ovi/wu/on/update 13,600 10,000 5.000 5.000 10,000 2.000 2,000 ,.mm /.mm 2.000 2,000 2.000 (yr /cooro.salary mos update p.r2'5mw extra mwmmo. P0610011. 1`91111m/ng yrs add m.mm/ ----------------------------------------'---------'-------'----'----'--'-----'--------'---------'------------'-'--- /wxwTmwCOMPONENT mm' /w.mo 115.000 73,000 13,000 125.000 53,000 13,000 63,000 61,000 61,000 55,000 56.000 -------------'---------------------------------------------'--'-------'--'-----'---'-------------'---'----- REmMMEwoom^GRwmmL w.nm.m, 15.20/.826 16.250.10111.106.92617.111,324 $8,250,994 18.01/.114 18.315.359 18.626.64/ 19.204.582 $9.10/.21/ 19.940./59 9.1 IL IL . �� C.-, �_ It U- t.^ a a OW M M 16mi L,&A N I I I I U F-- V- I I' I I I I I I I I I nmmv 200/ 2003 2004 2005 2005 2007 2008 2009TWENTY YEAR vURULm/VE mOGRmmmwnION COPPOKIN, =,.,..==,..,.,`,..,===.===,==`=.=.^,..=.=......=======,=============================.===================,,====== nE»/muuouE/MsTm Evaluation Coordinator n"n) 45,000 45,000 45,000 45.000 45,000 45,000 45,000 46.000 NOV Ewmt*"ww/wu"n/updam 5.000 5.000 5,000 5,000 5.000 5,000 5.000 5.000 HHV wnwct/w *w/wt~*yodsm 2.000 ».mm 2.000 2,000 2.000 2.000 2.000 21000 SQG Educat/wevolvit,o0"pdom 2.000 2.000 2.000 2.000 2,000 2.000 2.000 2.000 wmmnwu"* ww/wuwwupwm o o o o v o o o SOGoomp)wnce avImm*n/update 2.000 2.000 2.000 2.000 2.000 2.000 2.000 2.000 |r / w^*. salary from update w. r 2-5 from wu^ m$co~^. wm`tww. ,ww,mnj --------------------------------'------'-----------'--'----------'------'------'----------'-'------'-- yrs add m.mm> --------------------------------- Ewumnxmwxmwm/ TOTAL 56.000 56,000 56.000 56,000 56,000 56.000 55,000 66.000 ------------------ --------------------------'------------------------------------------------------------------------ REmxmmno"RmRAwTOTAL mo./m.m 110.213.y2 o10.432.53? 110,594.991 ^w./m.n/ w0.9311.44S mun.u^ 111,306,8511 $171,1110.6114 1993 1994 1995 1996 1991 1998 1999 2000 1,007 1989 1990 1991 1992 HHW COLLECTION COMPONENT SUPPLEMENTARY INFORMATION 8,493 8.01 HHW Tannage Generated 8,310 5,480 6,650 6,823 largeted waste diverted Oil 8.01 8.01 8.05 8.01 Oil Diverted itonsl 505 $18 532 548 Remaining HHW 5,805 5,952 6,118 8,211 Collection and Disposal (percent) 4.51 3.21 5.01 6.91 Toni 261 191 308 432 Collection and Recycling (percent) 0.01 5.85 9.05 12.15 ions 0 345 548 160 1993 1994 1995 1996 1991 1998 1999 2000 1,007 7,100 1,391 1,600 7,813 6,030 8,260 8,493 8.01 8.01 0.01 8.08 8.01 8.08 8.01 8.01 561 516 592 608 625 642 661 519 0,445 5,624 6,805 6,992 1,188 1,388 7,599 7,814 7.11 9.91 10.31 11.11 11.55 12.31 13.1% 13.55 494 854 701 115 829 909 994 1,054 13.35 17.15 19.15 22.95 25.55 26.11 31.91 34.56 860 1,134 1,341 1,603 1,830 2,120 2,426 2,698 Waste generated/ucerltons) 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 number of users $225 10131 11130 17853 21015 35710 40831 41546 $3191 60578 58393 75010 Pe nenent Sites 1 2 3 4 5 6 5 6 6 0 5 8 number of HE 13.0/user hour)/site 2 1.95 1.88 1.43 1,8 1.65 1.13 2.1 2.03 2.1 2.1 2.4 avg rate of ussage/hr 1.2 I.5 2.5 3.3 2.5 3.5 4.2 4.2 5.0 5.1 6.6 6.4 6 r open to public(wk 25 25 25 19 24 22 23 18 27 20 28 32 collection goal/year (tons) 81 351 497 653 814 1,248 1,502 1,837 2,120 2,489 1,880 3,211 mobile S tea 1 1 2 3 3 3 3 3 3 3 3 3 avg number of stafflftel/site 1 2 2 2 2 2 2 2 2 2 1 2 lumbar of users/hr 4 4 4 4 4 4 4 4 4 4 4 4 nrs open to public/wk 25 25 25 25 25 25 25 25 25 25 25 25 0 s/yr open to the public 35 36 36 38 36 36 36 36 36 36 36 35 collection goal/year (tons) 180 180 360 540 $40 540 540 $40 540 540 540 540 number of users/yr 3600 3600 1200 10800 10800 10800 10800 10800 10800 10800 10800 10800 f0 UL HHW waste collected Itons) 251 531 657 1,193 1,354 1,188 1,042 2,317 2,550 3,029 3,420 3,751 a N 00 I 1 I I I I I I I I I I I I I I I 1 I 2001 2002 2003 2004 2006 2006 2001 2008 2001 HIIW COLLECTION COMPONENT SUPPLEME14TARY INFORMATIO14 NNY Iennele Generated 8,.40 8,993 9,253 9,530 9,813 10,101 10,413 10,123 11,053 lerlated waste diverted 011 1.01 8.01 6.01 1.08 8.01 8.01 0.01 8.01 6.08 011 Diverted Itons) 191 119 140 162 165 609 833 858 884 Remalninl NNY 8,041 8,214 8,513 8,168 9,028 9,298 9,580 9,865 10,169 Collection And Disposal (percent) 11.11 12.88 12.21 11.91 11.81 11.85 11.81 11.81 11.11 lone 1,050 1,044 1,031 1,042 1,082 1,094 1,129 1,113 1,194 Collection end Recycllnl (percent) 34.91 35.41 35.81 36.15 30.25 36.25 31.I1 31.15 36.35 long 1,809 2,921 3,049 3,151 3,112 3,369 3,410 3,512 3,681 lest@ lenersted/user(tonel 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 number of users 11112 19426 81112 84169 86658 69255 91968 94101 91620 Permanent Situ 1 6 1 5 6 5 1 5 1 number of FIE (LO/user hurl/site 2.85 3 3 3 3 3 3 3 3 erl rete of usesle/hr 5.5 5.5 5.1 5.9 6.1 6.3 6.5 6.1 1.0 hrs open to public/■t 38 40 40 40 40 40 40 40 40 collection loll/year Itons) 3,320 3,431 3,540 3,668 3,293 3,923 4,058 4,195 4,341 Roblls Situ 3 3 3 3 3 3 3 3 3 Avl number of stsfflftel/site 2 2 1 2 2 2 2 2 2 number of users/hr 4 4 4 A 4 4 4 4 4 hrs open to public/0 25 25 25 25 25 25 25 25 25 was/yr open to the public 30 36 36 36 35 36 36 36 36 collection Joel/year Itons) $40 $40 540 $40 $40 540 $40 $40 540 number of users/yr 10800 10800 10800 10000 10800 10800 10800 10800 10800 IOIAI. HHV waste collected Itons) 3,810 3,911 41086 4,208 4,333 4,463 4,598 4,135 4,881 COORDINATOR JOB DESCRIPTIONS GENERAL DUTIES OF ALL COORDINATORS • Participate on staff committee, and make recommendations to Management Coordination Committee on annual implementation program. Review interagency agreement for implementation to ensure that overall program fits within the bounds and budget of the Plan; • Ensure that annual work plan is established in coordination with all component staff, reflecting program goals and priorities; • Track overall component costs and effectiveness, participate as necessary in regular evaluation, including definition of evaluation criteria and methodology, and recommend program revisions; • Ensure successful implementation of Plan components. HHW EDUCATION COORDINATOR (1 FTE -- Health Department) SQG EDUCATION COORDINATOR (1 FTE -- Metro) Manage educational and outreach programs: • coordinate with agency education staff in development and implementation of specific program elements. • ensure that materials/activities are consistent and complete. • maintain communication/information flow, so that all involved agencies know what educational opportunities are available, and have access to them. • develop and maintain on-going relationships with media, public organizations, business groups etc. to provide information and gather feedback. • Explore and assess the feasibility of education and outreach opportunities as they arise; assist program staff in prioritizing opportunities. HHW COLLECTION COORDINATOR (0.5 FTE -- King County Solid Waste Division) (0.5 FTE -- Seattle Solid Waste Utility) • Coordinate with local project managers to ensure regional consistency in data collection and management, and regional compliance with highest priority waste management strategies in disposal contracts. • Ensure regional promotion of collection services. • For permanent facilities: 1) actively promote the establishment of permanent facilities in suburban cities; 2) work with staff in host communities in performing siting process, site design and construction, equipment purchase, development of contracts for services, and in preparation of procedures and training as needed. • For mobile facilities: 1) oversee development of mobile units, and contracts for implementation; 2) ensure conformity with waste handling priorities and site set-up procedures for public and environmental protection; 3) choose operation locations and ensure equitable service throughout the region. • Research feasibility of special collection for targeted wastes; promote implementation of special services where appropriate. I: 1 �. SQG COLLECTION COORDINATOR (1 FTE -- King County) Develop RFP for collection facilities (mobile and auxiliary) and oversee contracts for implementation; • Ensure promotion of collection facilities; rDevelop RFP for design of subsidy program; oversee contract, and implement according to consultant recommendations. ' COMPLIANCE COORDINATOR (1 FTE -- Metro) • Facilitate interagency communication with regard to compliance programs. • Work with management and field staff in agencies not directly responsible for compliance programs to ensure their participation. • Provide staff support for and monitor the activities of the Interagency Regulatory Analysis Committee and Enhancement of Local Ordinances efforts. Ir. Monitor regulatory activities of the state and federal governments that have a bearing on HHW and SQG hazardous waste management. EVALUATION COORDINATOR (1 FTE -- Health, Metro, Seattle Long-range Planning) • Facilitate research design, identify data collection needs and development of RFPs for evaluation. • Manage evaluation contracts w. Conduct or manage contracts for baseline data collection (e.g., waste sorts, public awareness surveys, water quality testing). • Assure that results of evaluation efforts are given to Management Coordination ` Committee annually to contribute to annual work plan review and approval. BUDGETS AND CONTRACTS COORDINATOR (Health) rr • Oversee collection of solid waste and wastewater fees. I" Administer the accounts containing collected fees. Oversee the interagency agreements between the Health Department and other implementing agencies that permit disbursement of funds. ME L L I: it aw STAFFING COMMITMENTS -- 1990 Responsible .r Program Level Agency In Budget? New? HHW Education Coordinator 1 FTE Health 1 1 Info & Outreach Metro' 0 0.25 1 K.C. 1 1 Seattle 0.25 Waste Reduction 1 Metro 0 0.25 rw Seattle 0.25 Telephone Line (HHW only) 1 Health 1 Schools 2 Metro 0 0.5 K.C. 0.5 0.5 HHW Collection Coordinator Permanent 0.5 Seattle 0.5 Mobile 0.5 K.C. 1.32 0.8 Permanent Collection Staff 4 Seattle 4 3 Mobile Collection Staff 2 K.C. 2 contracted .rr SQG Education Coordinator 1 Metro 0 l Info Devel. & Resources 1.5 Metro 0.5 1 Resource Library 1 Metro 0.5 0.5 Telephone Line (SQG only) 1 Health 1 1 Waste Exchange 1.5 Health 1 0.5 Waste Reduction etc. 1 Metro 0 1 On -Site Consults 3 Metro 0 3 Waste Characterization 1 Metro 0 1 SQG Collection Coordinator 1 K.C. 0 1 SQG Collection Promotion 0.5 K.C. 0 0.5 Compliance Coordinator 1 Metro 0 1 "r Enhancement of Local Ords. 1 10 agencies IRAC 1 10 agencies Response Network 1 Metro 0 1 Field staff 1 Metro 0 1 Surveys 1 Metro 0 1 Audits 3 Health 3 3 Evaluation Coordinator 0.33 Metro 0 0.33 0.33 Health 0 0.33 0.33 Seattle (OLP)' 0 0.33 TOTAL 35.5 17.8 26 'Metro has a cap on filling new positions; at the same time the Metro Council adopts the Plan, they will authorize the new positions. ' Zinlcudes 0.3 FTE for targeted recycling 'This position cannot appear in the budget until a funding source has been identified; when the fee setting ordinances are adopted, OLP will go through the steps necessary to create this position. B-32 ' I. Solid Waste Interlocal Agreement B-33 This Agreement is entered into between King County, a political subdivision of the State of Washington and , a municipal corporation of the State of Washington, hereinafter re erred to as "County" and "City" respectively. This agreement has been authorized by the legislative body of each jurisdiction pursuant to formal action as designated below: King County: Motion No. 7143 AdCity: PREAMBLE This Agreement is entered into pursuant to chapter 39.34 RCW for the purpose of cooperative management of solid waste in King County. It is the intent of the parties to work cooperatively in establishing a solid waste management plan pursuant to Chapter 70.95 and with emphasis on the established priorities for solid waste management of waste reduction, waste recycling, energy recovery or incineration, and landfilling. The parties particularly support waste reduction and recycling and shall cooperate to achieve the goals established by the comprehensive solid waste management plan. The parties acknowledge their intent to meet or surpass applicable environmental standards with regard to the solid waste system. The parties agree that equivalent customer classes should receive equivalent basic services. I. DEFINITIONS For purposes of this Agreement the following definitions shall apply: "Basic Services" means services provided by the King County Department of Public Works, Solid Waste Division, including the management and handling of solid waste. "Comprehensive Solid Waste Management Plan" means the comprehensive plan for solid waste management as required by RCW 70.95.080. "Designated Interlocal Forum" means a group formed pursuant to the Forum Interlocal Agreement comprised of representatives of unincorporated King County designated by the King County Council, representatives of the City of Seattle designated by the City of Seattle, and representatives of other incorporated cities and towns within King County that are signators to the Forum Interlocal Agreement. "Disposal" means the final treatment, utilization, processing, deposition, or incineration of solid waste but shall not include waste reduction or waste recycling as defined herein. "Diversion" means the directing or permitting the directing of solid waste to disposal sites other than the disposal site designated by King County. "Energy/Resource Recovery" means "the recovery of energy in a usable form from mass burning or refuse derived fuel incineration, pyrolysis of any other means 4:v� -1- rt of using the heat of combustion of solid waste that involves high temperature (above 1,200 degrees F) processing." (WAC 173-304-100). "Moderate Risk Waste" means "(a) any waste that exhibits any of the characteristics of hazardous waste but is exempt from regulation under this chapter solely because the waste is generated in quantities below the threshold for regulation and (b) any household wastes which are generated from the disposal of substances identified by the department as hazardous household substances." (RCW 70.105.010) "Solid Waste" means all putrescible and nonputrescible solid and semisolid •• wastes, including but not limited to garbage, rubbish, ashes, industrial wastes, swill, demolition and construction wastes, abandoned vehicles or parts thereof, and discarded commodities but shall not include dangerous, hazardous or extremely hazardous waste. i "System" means King County's system of solid waste transfer stations, rural and regional landfills, energy/resource recovery and processing facilities as authorized by RCW 36.58.040, and as established pursuant to the approved King County Comprehensive Solid Waste Management Plan. "Waste Recycling" means "reusing waste materials and extracting valuable materials from a waste stream." (RCW 70.95.030) "Waste Reduction" means reducing the amount or type of waste generated but shall not include reduction through energy recovery or incineration. "Landfill" means "a disposal facility or part of a facility at which waste is placed in or on land and which is not a land treatment facility." (RCW '■ 70.95.030). II. PURPOSE 0 The purpose of this Agreement is to establish the respective responsibility of the parties in a solid waste management system which includes, but is not limited to: Planning, waste reduction, recycling, and disposal of mixed j municipal solid waste, industrial waste, demolition debris and all other waste defined as solid waste by RCW 70.95.030, and moderate risk waste as defined in RCW 70.105.010. -� III. DURATION This Agreement shall become effective on July 1, 1988, and shall remain in effect through June 30, 2028. IV. APPROVAL This Agreement shall be submitted to the Washington State Department of Ecology for its approval as to all matters within its jurisdiction. This Agreement an shall be filed with the City Clerk, with the Clerk of the King County Council and with the Secretary of State of the State of Washington. .r, -2- F•; V. REVIEW AND RENEGOTIATION B-35 5.1 Either party may request review and/or renegotiation of any provision of this Agreement other than those specified in Section 5.2 below during the six-month period immediately preceding the fifth anniversary of the effective date of this Agreement and during the six month period immediately preceding each succeeding fifth year anniversary thereafter. Such request must be in writing and must specify the provision(s) of the Agreement for which review/renegotiation is requested. Review and/or renegotiation pursuant to such written request shall be initiated within thirty days of said receipt. 5.2 Review and/or renegotiation shall not include the issues of system rates and charges, waste stream control or diversion unless agreed by both parties. 5.3 In the event the parties are not able to mutually and satisfactorily resolve the issues set forth in said request within six months from the date of receipt of said request, either party may unilaterally request the Forum to review the issues presented and issue a written recommendation within ninety days of receipt of said request by the Forum. Review of said request shall be pursuant to the procedures set forth in the Interlocal Agreement creating the Forum and pursuant to the Forum's bylaws. The written decision of the Forum shall be advisory to the parties. 5.4 Notwithstanding any other provision in this paragraph to the contrary, the parties may, pursuant to mutual agreement, modify or amend any provision of this Agreement at any time during the term of said Agreement. VI. GENERAL OBLIGATION OF PARTIES 6.1 KING COUNTY a. Management. King County agrees to provide county -wide solid waste management services for waste generated and collected within jurisdictions party to this Agreement. The County agrees to dispose of or designate disposal sites for all solid waste including moderate risk waste generated and/or ccllected within the corporate limits of the City which is delivered to King County in accordance with all applicable federal, state and local environmental health laws, rules, or regulations. b. lann'n . King County shall serve as the planning authority within King County for solid waste including moderate risk waste but shall not be responsible for planning for hazardous or dangerous waste or any other planning responsibility that is specifically designated by State or Federal statute. C. Operation. King County shall be or shall designate or authorize the operating authority for transfer, processing and disposal facilities, including public landfills, waste reduction or recycling facilities and energy resource recovery facilities as well as closure and post -closure responsibilities for landfills which are or were operated by King County. d. Collection Service. King County shall not provide solid waste collection services within the corporate limits of the City, unless permitted by law and agreed to by both parties. -3- e. Suaaort and Ast;stanra. King County shall provide support and technical assistance to the City if the City seeks to establish a waste reduction and recycling program compatible with the County wast@ reduction and recycling plan. The County shall develop educational materials related to waste reduction and recycling and strategies for maximizing the usefulness of the materials and will make these available to the City for its use. Although, the County will not be required to provide a particular level of support or fund any City activities related to waste reduction and recycling, King County intends to move forward aggressively to establish waste reduction and recycling programs, f. r c t. The County shall develop waste stream forecasts as part of the comprehensive planning process and assumes all risks related to facility sizing based upon such forecasts. 9• Facilities andService$. County facilities and services including waste reduction and recycling shall be provided pursuant to the comprehensive solid waste plan. All personal and real property acquired by King County for solid waste management system purposes shall be the property of King County. 6.2 CITY a. Collection. The City, an entity designated by the City or such other entity as is authorized by state law shall serve as operating authority for solid waste collection services provided within the City's corporate limits. b.LIP-01-41. The City shall by ordinance designate the County disposal system for the disposal of all solid waste including moderate risk waste generated and/or collected within the corporate limits of the City and shall authorize the County to designate disposal sites for the disposal of all solid waste including moderate risk waste generated or collected within the corporate limits of the City, except for solid waste which is eliminated through waste reduction or waste recycling activities consistent with the Comprehensive Solid Waste Management Plan. No solid waste generated or collected within the City may be diverted from the designated disposal sites without County approval. VII. COUNTY SHALL SET DISPOSAL RATES AND OPERATING RULES FOR DISPOSAL In establishing or amending disposal rates for system users, the County may adopt and amend by ordinance rates necessary to recover all costs of operation including the costs of handling, processing, disposal, defense and payment of claims, capital improvements, operational improvements and the closure of landfills which are or were operated by King County. King County shall establish classes of service for basic solid waste management services and by ordinance shall establish rates for users of each class. VIII. LIABILITY 8.1 Except as provided herein, the County shall indemnify and hold harmless the City and shall have the right and duty to defend the City through the County's attorneys against any and all claims arising out of the County's operations and to settle such claims, recognizing that all costs incurred by the County thereby are system costs which must be satisfied from disposal rates SE B-37 as provided in section VII herein. In providing such defense of the City, the County shall exercise good faith in such defense or settlement so as to protect the City's interest. For purposes of this section "claims arising out of the county's operations" shall include claims arising out of the ownership, control, or maintenance of the system, but shall not include claims arising out of the City's operation of motor vehicles in connection with the system or other activities under the control of the City which may be incidental to the County's operation. 8.2 If the County is not negligent, the City shall hold harmless, indemnify and defend the County for any property damages or personal injury solely caused by the City's negligent failure to comply with the provisions of Section 8.5.a. 8.3 In the event the County acts to defend the City against a claim, the City shall cooperate with the County. In the event the City acts to defend the County, the County shall cooperate with the City. 8.4 For purposes of this section, references to City or County shall be deemed to include the officers, employees and agents of either party, acting within the scope of their authority. 8.5.a. All waste generated or collected from within the corporate limits of the City which is delivered to the system for disposal shall be in compliance with the resource conservation and recovery act, as amended (42 U.S.C. 6901 et seq.), RCW 70.95, King County Board of Health Rules and Regulations No. 8, and all other applicable federal, state and local environmental health laws, rules or regulations. The City shall be deemed to have complied with the requirements of section 8.5.a. if it has adopted an ordinance requiring solid waste delivered to the system for disposal to meet such laws, rules, or regulations and by written agreement has authorized King County to enforce these within the corporate limits of the City. 8.5.b. The County shall provide the City with written notice of any violation of this provision. Upon such notice, the City shall take immediate steps to ramedy the violation and prevent similar future violations to the reasonable satisfaction of King County which may include but not be limited to removing the waste and disposing of it an approved facility. If, in good faith, the City disagrees with the County regarding the violation, such dispute shall be resolved between the parties in Superior Court. Each party shall be responsible for its attorney's fees and costs. Failure of the City to take the steps requested by the County pending Superior Court resolution shall not be deemed a violation of this agreement; provided, however, that this shall not release the City for damages or loss to the County arising out of the failure to take such steps if the Court finds that the City violated the requirements to comply with applicable laws set forth in this section. 8.6 City is not held harmless or indemnified with regard to any liability arising under 42 USC § 9601-9675 (CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) or as hereafter amended or pursuant to any state legislation imposing liability for cleanup of contaminated property, pollutants or hazardous or dangerous substances. -5- ■/ B-38 IX. FORUM no By entering into this Agreement, the County and City agree to enter into and execute a Forum Interlocal Agreement. Such agreement shall provide for the establishment of a representative Forum for consideration and/or determination 'M Of issues of policy regarding the term and conditions of this Solid Waste Interlocal Agreement. r X. COMPREHENSIVE PLAN 10.1 King County is designated to prepare the comprehensive solid waste management plan and this plan shall include the City's Solid Waste Management Comprehensive Plan pursuant to RCW 70.95.080(3). 10.2 The initial comprehensive plan prepared under the terms of this Agreement shall be submitted to the King County Council and the designated interlocal Forum by December 31, 1988. The plan shall be reviewed and any necessary �+ revisions proposed at least once every three years following the approval of the Comprehensive Plan by the State Department of Ecology. From the effective date of this Agreement until the 1988 plan is approved, the 1974 Solid Waste Management Plan as approved in 1977 by DOE shall be used to meet the requirements of RCW 70.95.185 as directed by the State Department of Ecology. King County shall provide services and build facilities in accordance with the adopted Comprehensive Plan. 10.3 The Comprehensive Plan will promote waste reduction and recycling in accordance with Washington State solid waste management priorities pursuant to aw chapter 70.95 RCW, at a minimum. 10.4 The comprehensive solid waste management plan will be prepared in no accordance with chapter 70.95 RCW and solid waste planning guidelines developed by the Department of Ecology. The plan shall include, but not be limited to: a. Descriptions of and policies regarding management practices and facilities sm required for handling all waste types; b. Schedules and responsibilities for implementing policies; aw C. Policies concerning waste reduction, recycling, energy and resource recovery, collection, transfer, long-haul transport, disposal, enforcement and administration; ,.. d. Operational plan for the elements discussed in Item c above. 10.5 The cost of preparation by King County of the Comprehensive Plan will be .o considered a cost of the system and financed out of the rate base. 10.6 The Comprehensive Plan will be adopted when the following has occurred: No a. The Comprehensive Plan is approved by the King County Council; and b. The Comprehensive Plan is approved by Cities representing three-quarters of the population of the incorporated population of jurisdictions that are parties to the Forum Interlocal Agreement. In calculating the three-quarters, the calculations shall consider only those incorporated jurisdictions taking formal -6- LM action to approve or disapprove the Plan within 120 days of receipt of the Plan. The 120 day time period shall begin to run from receipt by an incorporated jurisdiction of the Forum's recommendation on the Plan, or, if the Forum is unable to make a recommendation, upon receipt of the Comprehensive Plan from the Forum without recommendation. 10.7 Should the Comprehensive Plan be approved by the King County Council, but not receive approval of three-quarters of the Cities acting on the Plan, and should King County and the Cities be unable to resolve their disagreement, then the Comprehensive Plan shall be referred to the State Department of Ecology and the State Department of Ecology will resolve any disputes regarding Plan adoption and adequacy by approving or disapproving the Comprehensive Plan or any part thereof. 10.8 King County shall determine which cities are affected by any proposed amendment to the Comprehensive Plan. If any City disagrees with such determination, then the City can request that the Forum determine whether or not the City is affected. Such determination shall be made by a two-thirds majority vote of all representative members of the Forum. 10.9 Should King County and the affected jurisdictions be unable to agree on amendments to the Comprehensive Plan, then the proposed amendments shall be referred to the Department of Ecology to resolve any disputes regarding such amendments. 10.10 Should there be any impasse between the parties regarding Plan adoption, adequacy, or consistency or inconsistency or whether any permits or programs adopted or proposed are consistent with the Comprehensive Plan, then the Department of Ecology shall resolve said disputes. XI. FORCE MAJEURE The parties are not liable for failure to perform pursuant to the terms of this Agreement when failure to perform was due to an unforeseeable event beyond the control of either party to this Agreement. XII. MERGER This Agreement merges and supersedes all prior negotiations, representation and/or agreements between the parties relating to the subject matter of this Agreement and constitutes the entire contract between the parties except with regard to the provisions of the Forum Interlocal Agreement. XIII. WAIVER No waiver by either party of any term or condition of this Agreement shall be deemed or construed to constitute a waiver of any other term or condition or of any subsequent breach whether of the same or a different provision of this Agreement. _7. is - X XIV. THIRD PARTY BENEFICIARY This Agreement is not entered into with the intent that it shall benefit any other entity or person except those expressly described herein, and no other such person or entity shall be entitled to be treated as a third party beneficiary of this Agreement. XV. SEVERABILITY If any of the provisions contained in this Agreement are held illegal, invalid or unenforceable, the remaining provisions shall remain in full force and effect. XVI. NOTICE IN WITNESS WHEREOF this Agreement has been executed by each party on the date set forth below: CITY KING COUNTY MAYOR KING COUNTY EXECUTIVE DATE: DATE: PURSUANT TO ORDINANCE NO. PURSUANT TO ORDINANCE NO. CLERK - ATTEST CLERK - ATTEST No APPROVED AS TO FORM AND LEGALITY APPROVED AS TO FORM AND LEGALITY CITY ATTORNEY ING COUNTY DEPUTY PROS EC——I—NG —ATTORNEY DATE: DATE: c33modelsw4 This Agreement is entered into between King County, a political subdivision of the State of Washington, the City of Seattle, and the cities and towns set forth below, all municipal corporations located within the boundaries of King County, hereinafter referred to as "County" and "Cities". This Agreement has been authorized by the legislative body of each jurisdiction pursuant to formal action as designated on the signature pages. INFITTI.% This Agreement is entered into for the purposes of establishing a Forum composed of representatives from the Cities and the County that will consider issues of policy regarding terms and conditions of the Solid Waste Interlocal Agreement entered into individually between each City and the County. II. PURPOSE The purpose of this Agreement is to establish the Forum and the terms and conditions by which the parties shall discuss and/or determine policy and development of a Comprehensive Solid Waste Management Plan. III. DURATION This Agreement shall become effective on July 1, 1988, and shall remain in effect through June 30, 2028. IV. APPROVAL This Agreement shall be submitted to the Washington State Department of Ecology for its approval as to all matters within the Department's statutory jurisdiction, if any. This Agreement shall be filed with each City clerk, with tha Clerk of the King County Council, and the Secretary of State of the State of Washington. V. SCOPE OF RESPONSIBILITIES The scope of the responsibilities of the Forum is as follows: 1. Advise the King County Council, the King County Executive and other jurisdictions as appropriate, on all policy aspects of solid waste management and planning. 2. Consult with and advise King County Solid Waste Division on technical issues related to solid waste management and planning. 3. Review and comment on alternatives and recommendations for King County comprehensive solid waste management plan and facilitate a review and/or approval of the plan by each jurisdiction. -1- 4. Review subsequent proposed interlocal agreements between King County and Cities for planning, waste recycling and reduction, and waste stream control. 5. Review and comment on disposal rate proposals. =1 6. Review and comment on status reports on waste stream reduction, recycling, energy/resource recovery and solid waste operations with interjurisdictional impact. 7. Promote information exchange and interaction between waste generators, local government with collection authority, recyclers and County planned and operated disposal systems. 8. Provide coordination opportunities between King County Solid Waste Division, Cities, private operators and recyclers. 9. Aid Cities in recognizing municipal solid waste responsibilities, including collection and recycling, and effectively carrying out those responsibilities. VI. MEMBERSHIP 6.1 The Forum shall consist of a 12 member group of representatives of unincorporated King County designated by the King County Council, representatives of the City of Seattle designated by the City of Seattle, and representatives of other incorporated cities and towns within King County that are signators to this agreement designated by the Suburban Cities Association. Members of the Forum shall be established on the most current population estimates as published by the Washington office of Financial Management. Currently, unincorporated King County composes 41 percent; Seattle, 36 percent; and Suburban Cities, 23 percent of the total population. The calculations are determined as follows: Members Unincorporated King County 12 x 41% - 4.92 5 Seattle 12 x 36% - 4.32 4 Suburbs 12 x 23% - 2.76 1 Total 12 t Chair 6.2 In calculating the number of representatives on the Forum, all numbers .5 and greater are to be rounded up to the nearest whole number. Proportional representation of the Forum will be reviewed once every five years during the life of this agreement and necessary revisions shall be made to the proportional representation according to the formula set forth above based on population change as established by the most current census. 6.3 In addition to the 12 members of the Forum, a citizen chair shall be selected or removed by a majority vote of all members of the Forum. Each representative shall have an equal vote on all Forum decisions. the Chair shall vote only in the case of a tie on any vote of the Forum. - 2 - VII. MEETINGS Unless otherwise provided, Roberts Revised Rules of procedural matters related to the business of the Forum. minimum of two meetings each year and not less than 14 da shall be given to members prior to such meeting. Four or Chair may declare an emergency meeting with 24 hours writ members. The first meeting shall be held no later than M time, date and location shall be set by King County after representatives of Seattle and the other cities and towns VIII. BYLAWS B-43 Order shall govern all There shall be a ys written notice more members or the ten notice to the arch 1, 1988, and the consultation with the 8.1 The Forum shall, within sixty days after its first meeting, adopt bylaws for the operation of the Forum. Such bylaws shall recognize that this Forum shall function in the place of the Puget Sound Council of Governments Committee on Solid Waste and the Solid Waste Management Board of the King Sub -regional Council. This Interlocal Forum shall not report to nor have responsibilities to or for either committee or council. The King County Solid Waste Advisory Committee formed pursuant to RCW 70.95.165 shall continue pursuant to its statutory functions and, in addition, shall advise the Forum on solid waste matters. 8.2 The bylaws shall provide, among other things, that the Forum shall make an annual written report to the public, and the parties to this Agreement on Forum activities and the status of the solid waste systems in King County. The bylaws may also provide for such other reports as deemed necessary. 8.3 The bylaws shall also provide for the manner in which the Forum will provide its consultative and participatory advice regarding the solid waste - management plan. IX. STAFFING AND OTHER SUPPORT Staffing, supplies and equipment for the Forum shall be supplied by and through the Puget Sound Council of Governments, its successor, or other entity. Reimbursement to the Puget Sound Council of Governments for such staffing, supplies and equipment shall be agreed upon and paid by King County from monies collected from the solid waste rates and charges, after considering recommendations by the Forum to King County. The Forum shall submit an appropriation request to the County by May 31 of each year or such other y,- mutually agreed upon date. King County may, subject to approval by a two-thirds vote of all constituted representatives of the Forum, terminate the staffing with Puget Sound Council of Governments and provide such staffing, supplies and equipment by other means. X. FORCE MAOEURE The parties are not liable for failure to perform pursuant to the terms of this Agreement when failure to perform was due to an unforeseeable event beyond the control of any party to this agreement. -3- XI. nnu B-44 This Agreement merges and artleserelatingprior theesubjectomatterrafethision and/or agreements between thep Agreement and constitutes the entire contract aste Intebetween the parties except With regard to the provisions of the Solid XII. WAIVER No waiver by either party of teYatwamver ofor nanYiother term orrconditlonaor be deemed or construed to constitu any subsequent breach, whether of the same or a different provision of this Agreement. This Agreement is not entered thoseto with expresslyintent descrlbed hersinllandbenefit any other entity or person, exce other such person or entity shal be entitled to be treated as a third party beneficiary of this Agreement. XIV. t WARI.ITY If any of the provisions contained iAgreement remaineln fullgfarce invalid or unenforceable, the remaining provisions and effect. IN WITNESS WHEREOF, this Agreemenhas executed set fortho.n the date set forth below, pursuant to thelegislative CITY Mayor Date Pursuant to Ordinance No. Clerk -Attest Approved as to form and legality City Attorney ate KING COUNTY King County ecut ve ate Pursuant to Ordinance No. Clerk -Attest Approved as to form and legality King County Deputy Prosecuting Attorney 4 pate c33-forumsr. -- z R 1 SUMMARY OF COMMENTS FROM THE SEATTLE -KING COUNTY LOCAL HAZARDOUS WASTE MANAGEMENT PLAN r. WORKSHOP FOR SUBURBAN CITIES t 119 Sponsored by: King County Metro City of Seattle Seattle -King County Department of Public Health June 7, 1989 D-1 TABLE OF CONTENTS D-2 1 r INTRODUCTION 1 GENERAL COMMENTS AND SUGGESTIONS 2 SERVICES 3 EDUCATION 4 ROUND -UPS 5 COSTS, RATES, BILLING PROCEDURES 5 SMALL QUANTITY GENERATORS 7 PERMANENT FACILITIES 7 MOBILE FACILITIES 9 APPENDICES Appendix A: Handout Packet Appendix B: Follow -Up Letter to Suburban Cities AM am D-3 Summary of Comments from the Seattle -King County Local Hazardous Waste Management Plan Workshop for Suburban Cities INTRODUCTION A workshop for representatives of the suburban cities was held the evening of June 7, 1989, in hearing room #2 at King County Building and Land Development in Bellevue. The purpose of the workshop was to discuss specific recommendations for implementing and funding local hazardous waste programs. Eleven cities were represented: Bellevue, Clyde Hill, Enumclaw, Hunts Point, Issaquah, Kirkland, Medina, Mercer Island, Redmond, Renton, and Yarrow Point. The workshop was hosted by the Technical Planning Committee and moderated by Pam Bredouw of Shapiro and Associates, Inc. Information was presented on the following topics: • Management Plan Update - Martha Burke, Seattle Office for Long- range Planning • Recommended Preferred Alternative - Dave Galvin, Metro • Suggested Financing Options - Todd Yerkes, Seattle -King County Department of Public Health • Proposed Implementation Strategy - Scott Blair, King County Solid Waste Division • Adoption Procedure - William Green, Department of Ecology A packet of handouts supplementing the speakers' comments was distributed to all participants (see Appendix A). Copies of the handout packet and a cover letter (see Appendix B) were mailed to all jurisdictions the day after the workshop to elicit further comments and questions. A question and answer period followed the presentations. Below is a summary of the questions and comments from the participants (organized 1 1 by subject), and the accompanying responses from the Technical Planning Committee. GENERAL COMMENTS AND SUGGESTIONS • There needs to be public education BEFORE the cities are asked to approve the Plan.. It would greatly help the cities in handling the concerns of the citizens. • From the suburban cities' viewpoint, it would be helpful to have a flow chart of the hierarchy of who would be in charge, how many people are involved, and the range of salaries of the staff all the way down to the level of inspector. The suburban cities are concerned about another layer of staff and how that relates to the money customers are putting into the Plan. They would like to know how much money is going for staff and how much is actually going toward implementation. • There should be more involvement from the Suburban Cities. The opinions expressed by tonight's participants may not be the same as those of the Suburban Cities. • There should be an interlocal agreement where cities decide who should attend the Plan's management meetings and represent their interests. The Management Committee that will oversee the Plan will have representation from the Suburban Cities. During much of the Plan development, the Suburban Cities were represented on the Technical Planning Committee. Cynthia Pruitt -Davidson, from the City of Redmond, represented all of the Suburban Cities. Unfortunately, such responsibility is not included in city budgets and after a while Cynthia was no longer able to continue. No other representative was sent to replace her. • Look into the way in which the Washington Citizen Insurance Authority operates. This could provide a method for structuring the involvement of the suburban cities in managing the Plan. • The Seattle -King County Hazardous Waste Management Plan should mention the King County Comprehensive Solid Waste Management Plan ■ and how they work in conjunction with each other. Likewise. the City D-5 of Seattle's Comprehensive Plan should mention the Hazardous Waste Plan. The final Seattle -King County Local Hazardous Waste Management Plan will discuss how it coordinates with the King County Comprehensive Solid Waste Management Plan. Seattle will do the same. SERVICES • Who will provide the services to the cities? King County is responsible for providing services to those cities that signed the Interlocal Agreement. Cities, however, can participate in Plan implementation if they so desire. Metro and the Health Department also may be involved with the small quantity generators. • If Bellevue establishes its own program, can adjacent cities choose to have Bellevue handle their hazardous waste? If Bellevue's (or any city's) program is funded by the Plan, it must be open to all County residents. Cities that adopt the Plan do not need to identify or provide services for their own residences, unless they want to. I• Are there boundaries for services? No. Citizens will be able to take their hazardous waste to any facility funded under the Plan in the County. • Does the Plan address suppliers taking back unused products that would become hazardous waste if discarded (paint, batteries, used motor oil)? The Plan discusses collection and recycling of batteries at the point of sale in the Targeted Waste parts of the program. As part of the used motor oil program, we will be looking at finding more collection sites (such as gas stations), as well as the possibility of curbside collection. (Recycled used motor oil is not considered a hazardous waste.) Programs for other recyclable wastes (such as latex paint) will probably not involve suppliers. 3 M • • Will it be possible to use existing inspectors? Yes. As part of our Response Network, a general inspection form is being developed for use by building inspectors, fire departments, Metro, etc. A fire inspector who notices a potential problem with a water pipe when he is conducting his fire inspection will fill out a portion of the form, turn it into the Response Network, and it will be forwarded on to the proper department or agency. There will be cross -training (paid) for all inspectors; however, this is not intended to create "one- stop" inspections but allow a method for alerting proper agencies when potential problems exist. If something does not look right, there would be a mechanism to report it. EDUCATION • Explain why the Plan allocates increasing amounts of money to education and waste reduction over the years. The Plan proposes a two-pronged approach: (1) long-term through education, reduce the amount of hazardous waste being produced, and (2) short-term, handle the large amounts of waste currently in the community. Pound for pound, education is more cost-effective than collection and disposal. • Given the increasing costs over the years, do you expect increasing amounts of hazardous waste to be generated even after the education measures are implemented? Costs will naturally go up over time as the Plan addresses a larger percentage of the waste. During the first year, only 10% is being addressed. If we decided that, as of January 1990, we would keep all hazardous waste out of the landfills, we would have to implement a program that would cost $12 million immediately. Such a significant amount all at once would have serious impact on ratepayers. Also, the Plan takes into consideration that the population of the County will increase over the years. Therefore, even if individuals generate less waste, there will be more of them contributing to the total amount. S ROUND -UPS D-7 • How much hazardous waste was collected at the last two round -ups? Approximately 1-3% of what is in the waste stream. • Why does the Plan recommend discontinuing round -ups? The Plan recommends that round -ups not be held on a regional basis, as in the past. Our ability to handle the waste in this manner is at capacity. Events held on the same day are not serving enough people well enough. This does not, however, preclude individual cities sponsoring local round -ups. COSTS, RATES, BILLING PROCEDURES FOR HOUSEHOLD HAZARDOUS WASTE • How will the funds to pay for this program be raised? Will users of the collection facilities be charged? Most likely, there will be no direct charge to use collection facilities for household hazardous waste; a charge would act as a disincentive. Also, it is not possible to charge what it actually costs to collect and dispose of the hazardous waste. Solid waste haulers will be charged and most likely they will pass this cost on to their customers; therefore, citizens will be paying for the services through increased bills. • What is the billing procedure? What amount will be tacked on by the contractors ? Contractors will be charged based on their accounts. The contractors will then pass the charges along to their customers, if they so choose. Cities will receive the same information as a double-check of the figures. 5 IM • In the survey you conducted last summer, what rates were people willing to pay? There was no survey question about rates. People did mention that they would be willing to pay a user fee of up to $5. • People are going to start complaining more and more about increased rates. How can the cities explain it to their citizens' satisfaction? Provide them with an option of a variable can rate for their garbage. By recycling, they will reduce the amount of garbage produced and therefore the amount paid. It is recognized that this will not be a significant drop because a large portion of the cost is for collection, which is a fixed cost. The Plan calls for a gradual increase in level of service, so rates do not dramatically increase all at once. Clark County had a similar situation with increasing rates. The citizens were charged $9 to pay for clean-up of the old landfill, which had been placed on the National Priorities List (the EPA's published list of the most serious abandoned or otherwise uncontrolled hazardous waste sites nationwide, identified for possible remedial cleanup under i the Comprehensive Environmental Response, Compensation and Liability Act [CERCLA or Superfund]). Shortly thereafter, they were assessed $.75 for the hazardous waste plan implementation. At a public meeting, one man commented that he would rather pay $.75 now to manage the waste going into the new landfill than be charged another $9 or more a few years down the road to clean up another NPL site. When looking at the Plan's 1990 budget for household hazardous waste, a large portion of the first year's cost is already included in existing budgets, so the incremental increase is not great. • What would it cost a city to operate its own facility? There are no comprehensive figures, but cities will be reimbursed for the program. However, this does not mean that cities will be given a blank check. Cities will have to develop capital and operating budgets, submit them to the Management Committee for review and approval. If M • their program is compatible with the Plan then an agreement would be made between the city and the Health Department to provide appropriate reimbursement. SMALL QUANTITY GENERATORS • Explain the assistance to small businesses and the costs to those businesses. The Plan proposes to provide and pay for technical assistance to businesses upon request. This will allow a small quantity generator to call and ask for assistance in order to adjust his manner of operating. There will be no charge for the assistance. The first five years of the SQG program will be the most expensive because of the satellite and mobile facilities, and disposal cost subsidy. • Concern was expressed about the inequity of charging the homeowners to subsidize the small quantity generators. Funding for the SQG program will come from small quantity generator revenues; households will not be subsidizing small quantity generators. SQG collection facilities will be funded for the first five years. After that time, it is expected that private industry will take over. The subsidy of collection costs for SQGs will be in effect through 1994, after which it will be discontinued and SQGs will be responsible for the entire waste management cost. The subsidy is intended to help defray the costs of disposing of small quantities of hazardous waste; currently, costs are high, especially when analysis is included. PERMANENT FACILITIES • How does the Plan fit in with the State plan for siting hazardous waste facilities? These are two separate plans that deal respectively with small and large quantities of hazardous waste: our Hazardous Waste Management Plan, and the State's plan for siting hazardous waste facilities (describes how to manage the actual waste and includes siting criteria). Different issues are covered in the plans: however, the 7 D-10 State's siting criteria could be used in siting our proposed permanent facilities. Local jurisdictions would have the ultimate authority to approve or disapprove siting within city limits based on their own criteria. • Who has the ultimate authority when there are conflicts with local codes? Local jurisdictions have the ultimate authority. The State and County have to comply with the local land use, zoning and fire department permit regulations. • How will the permanent sites be determined? The Plan doesn't designate where the permanent sites will be located. Recommendations will be made by a Management Committee that will receive input from staff coordinators whose responsibility it will be to see that certain levels of service are provided countywide. Cities who ask for sites will be addressed first, followed by other cities being contacted to see if they would consider locating a facility in or near their city. • What is the timeframe for approving a permanent site? The first site (South Transfer Station) took about eight months. For the second site in north Seattle, we anticipate about a year-long process from site selection to operation. The experience of these two will help streamline the process for the remaining sites. • Hasn't the deadline already passed for cities to adopt the siting criteria (zoning and land use) ? The State Legislature has extended the deadline to November 30, 1991. • Has Renton been ruled out as a possible site for a permanent facility? No. Any city may request to be considered for a permanent site. r MOBILE FACILITIES D-11 • When will the mobile units be phased in? If the Plan does not propose to hold further round -ups, cities need to know where to tell their citizens to take hazardous waste. We anticipate having one mobile facility operating by fall 1989, with two more within the next couple of years. Currently, there is one permanent site at the South Transfer Station, and the City of Seattle is now in the process of siting a second one in the north end. Other permanent facilities will be sited. Needs and costs are being balanced so as not to have a rapid increase in fees. According to information we received from the surveys last summer, people are willing to drive up to 10 miles to dispose of their hazardous waste. Using that information, we placed 10 -mile radius circles around the County and determined that six permanent facilities would meet this driving distance requirement. The purpose of the mobile units is to service the areas not included within the 10 -mile radius of a permanent facility. • Scheduling of the mobile facility will be important. When scheduling the mobile facility, we will make sure all communities have access to it. The facility will be scheduled throughout the County, e.g., Vashon for approximately two weeks and then Issaquah two weeks, etc. • Will the mobile facilities be staffed and are there plans to handle waste that is dropped off at the site after the unit is moved? These are issues that need to be addressed. We will be contacting many of the 29 states that currently have permanent hazardous waste sites to learn how they have handled these issues. It would be better to have hazardous waste dropped off at a closed site rather than dumped down the drain. This issue, however, is one that will be addressed. 9 D- 12, • Won't it be difficult to find locations for the mobile facilities? Mobile facilities will probably not be located in residential areas. Commercial or industrial areas within easy access of residential communities would be preferable. Citizen and City Council concern about liability and risk will be addressed in siting. Florida has been operating mobile facilities statewide for three to four years; their program is very similar to the one we are proposing. Most of their sites have been in commercial parking lots, like a Southcenter. We will be consulting them to see how their program operates. 10 III I 2 I LI Distribution List Final Local Hazardous Waste Management Plan State Agencies Office of the Governor Department of Ecology Department of Transportation Department of Commerce and Economic Development Department of Social and Health Services Utilities and Transportation Commission Planning and Community Affairs Joint Select Committee on Preferred Solid Waste Management Puget Sound Water Quality Authority King County L King County Executive King County Council Department of Solid Waste Department of Parks, Planning and Resources Development ,,s Municipality of Metropolitan Seattle (METRO) Metro Council .. Executive Director Office of Water Quality City of Seattle Mayor's Office Office for Long -Range Planning Engineering Department, Solid Waste Utility Department of Human Resources Fire Department Suburban Cities City of Auburn City of Algona City of Beaux Arts Village City of Bellevue City of Black Diamond City of Bothell City of Brier 1 L a City of Carnation City of Clyde Hill City of Des Moines City of Duvall City of Enumclaw City of Hunts Point City of Issaquah City of Kent City of Kirkland City of Lake Forest Park City of Medina City of Mercer Island City of Milton City of Normandy Park City of North Bend City of Pacific City of Redmond City of Renton Md City of Skykomish City of Snoqualmie City of Tukwila to City of Yarrow Point W Regional Agencies Puget Sound Council of Governments Port of Seattle Tribes M Duwamish Tribe Muckleshoot Tribe Tulalip Tribe Citizens Groups Ow Alliance for Solid Waste Alternatives County Citizens for Responsible Waste Management Leagues of Women Voters - King County Metro Citizen Water Quality Advisory Committee The Mountaineers Puget Sound Alliance Seattle Audubon Society Vashon Island Groundwater Management Advisory Committee Washington Environmental Council Washington Toxics Coalition I I'll 0