HomeMy WebLinkAbout01/17/1989, 6 - CONSIDERATION OF FINAL DRAFT OF COUNTY HAZARDOUS WASTE MANAGEMENT PLAN (CHWMP) Date:' 1/17/89
city o� san-tui s OBISPO ITEM NU BER:
COUNCIL AGENDA REPORT
FROM Michael Dolder, Fire Chief
SUBJECT:Consideration of Final Draft of County Hazardous Waste Management Plan
(CHWMP)
CAO RECOMMENDATION:
A) By resolution, disapprove the County Hazardous Waste Management Plan
(CHWMP).
B) Following distribution of the certified EIR, reconsider approval or
disapproval of the County Hazardous Waste Management Plan before
3/10/89.
BACKGROUND:
Assembly Bill 2948 sponsored by Sally Tanner was approved by the Governor on
September 30, 1986. The law, commonly known as the Tanner Bill, was amended
numerous times and authorizes a county in lieu of preparing the hazardous waste portion
of the Solid Waste Management P1-n, to approve by February 1, 1989 a County Hazardous
Waste Management Plan based on guidelines adopted by the Department of Health
Services. The bill also provides that development project approval provisions apply to
the making of land use decisions for a hazardous waste facility project which is not a
land disposal facility. The Tanner Bill establishes a procedure for appealing local agency
land use decisions concerning the siting, construction or expansion of an off-site
hazardous waste facility serving more than one hazardous waste generator.
Existing law requires the Coam,6 of San Luis Obispo to have the revised CHWMP
approved by a majority of the cities within the County which contain a majority of the
population of the incorporated lrea of the County before 2/1/89. If a city takes no
action on the plan it is assumed ihat the plan is approved.
The City of San Luis Obispo in May of 1988, reviewed the preliminary draft of the
CHWMP. As a result of this review, numerous questions regarding the plan were
forwarded to the Waste Management Commission for consideration in the revisions to the
plan, Attachment #1.
The final draft of the CHWMP was completed in November, 1988 and incorporated
suggestions received from interested parties. A draft Environmental Impact Report on
the CHWMP, dated October, 1988, was completed by Engineering Science in compliance
with CEQA guidelines. The deadline for written comments on the EIR ended December 9,
1988. The final EIR will not be available until 2/7/89. The Board of Supervisors will
certify the EIR shortly thereafter.
The CEQA requirements and the time-line established by the Tanner Bill are in conflict.
The Tanner Bill requires that cities and a county adopt the CHWMP by 2/1/89. Section
15096 of the CEQA guidelines requires responsible agencies to consider an environmental
document when approving the plan. However, a certified EIR will not be available until
after 2/7/89. Various time extensions have already been requested by the County; the
last request was made Nov. 10, 1988, Attachment #2. In addition, Sally Tanner has
introduced urgency legislation to extend the approval deadline until 5/1/89. Neither the
County's request nor the legislation have been approved and the state deadline of 2/1/89
remains in affect. A comparison of state and county timelines are found in Table-1.
6 /
m � i�lllllll�pa�°o����Il City O� San LUIS OBISPO
MoGs COUNCIL AGENDA REPORT
Table-1
Comparison of Approval Time Lines
State County County
Requirement Timeline #1 Timeline #2
Cities Receive Final CHWMP 10/15/88 to 11/17/88 11/17/88
to begin 90 day Review 11/1/88
and Approval
Cities Complete 90 day 1/15-1/31/89 2/17/89 3/10/89
Review Period
Board of Supervisors Approve 2/1/89 2/21/89 3/14/89
and Send Final CHWMP to DOHS
Final EIK-Available 1/31/89 2/7/89
Board Certifies EIR 2/21/89 2/21/89
DOHS Approves or Denies CHWMP 7/31/89 7/31/89 7/31/89
Cities ind County Adonts 2/1/90 2/1/90 2/1/90
CHWMP (180 Days)
County Hazardous Waste Management Plan:
The complete Hazardous Waste Management Plan is divided into two parts; the plan
itself and technical appendices. The executive summary of the plan, Attachment #3,
covers the fifteen elements specified by the Tanner Bill. The elements of the plan are
as follows: Introduction; Purpose, Goals and Objectives; Current Waste Generation;
Projected Waste Generation; Treatment, Storage or Disposal Facility; Shortfalls; Facilities;
Waste Reduction; Siting; Transportation Plan; Implementation; Emergency Response
Procedures; Storage Regulations; Contaminated Sites; Small Quantity Generators; and
Household Hazardous Waste.
Rev Issues of the Plan:
The fundamental policy of the plan (pg 3-4) is that new offsite hazardous
waste management facilities will be limited to a scale necessary to meet the
hazardous waste needs of this County; larger facilities may be permitted if
agreements are made and the project meets local planning criteria and serves
public needs.
��� ��►►►�NIfIiI�PA!��Ili city of San LUIS OBISpo
Maiffs COUNCIL AGENDA REPORT
This policy language, although not accepted y the Department ol Health
Services, is consistent with the County Supervisor's Association of California
(CSAC) position. If the Department of Health Services rejects the policy
language it will be rejecting approximately 40 other County policies as well.
A hierarchy for a preferred waste management system is established (pg 3-5)
with source reduction being the most preferred and disposal facilities as the
least preferred option.
San Luis Obispo County does not generate sufficient hazardous waste to
support one of the seven generalized treatment facilities (pg 7-9). A local,
small-scale transfer station might operate as a collection center for route
service haulers.
The plan emphasizes waste reduction (Chapter 8, pg 8-1) and defines where we
are and where we can expect to be in the future.
The Tanner Bill requires siting guidelines be established for any of the
hazardous waste facilities. The CHWMP Plan addresses San Luis Obispo County
siting criteria and policy in Chapter 9 (pg 1-1).
Hazardous Waste Facilities fall into three categories (pg 9-2):
1) Transfer and Storage Facilities (pg 9-2)
2) Treatment Fac.lities (pg 9-3)
3) Residual Repositories (pg 9-5)
The actual siting criteria mandated by the Department of Health Services siting
criteria are found on pgs. (9-6 to 9-12).
The CHWMP identifies rene-al areas where hazardous waste facilities may be
located (Fig 9-1). However, for purposes of completing the EIR, study areas
were specifically identified and discussed. Copies of the specific study areas
are attached in Figures III.2, IIL3, III.4, IILS, III.6 and III.7. These specific
boundaries are not contained in the CHWMP. Alternative siting arrears have
been recommended in the EIR. These alternatives are listed in Attachment #4
will be incorporated into the revised EIR and the County CHWMP for
consideration during final CHWMP approval by the cities and county.
Five implementation activities are described in the plan beginning on pg 11-1
and as follows:
1) Educate the public and local industries j
2) Develop household waste disposal options
3) Reduce the volume of waste
4) Provide proper locations for new or expanded waste facilities
5) Amend City and County General Plans (pg I1-7)
Household hazardous waste is an important element of CHWMP. The plan
emphasizes a significant effort to address the problem of educating the
community. The Hazardous Waste Commission has formed a sub-committee to
deal with the implementation of a household waste program and the sub-
committee continues work on developing recommendations for a County-wide
collection program.
� �3
city of San Luis OBispo
A
NftZa COUNCIL. AGENDA REPORT
Aonroval of the Plan:
The goal is for the cities and county to approve CHWMP. However, distribution dates of
the CHWMP and the EIR will not allow the approvals to be completed by the 2/1/89
state deadline. To protect the cities approval rights and to keep our options open, two
actions are recommended.
Action 1. Disapprove the CHWMP before 2/1/879 based on the fact that a certified EIR
is not available. The disapproval will be conditional and will be reconsidered
when the certified EIR is issued.
Action Following the distribution of the certified EIR and before 3/10/89, the Council
should reconsider approval or disapproval of the CHWMP.
ALTERNATIVES:
Alternative 1. A) By resolution disapprove the CHWMP before 2/1/89, based on
the unavailability of a certified EIR.
B) Following the distribution of the certified EIR reconsider
approval or disapproval of the CHWMP before 3/10/89.
Alternative 2. By resolution approve the CHWMP as is.
Alternative 3. By resolution disapprove the CHWMP and take no further action.
Alternative 4. Take no action on the CHWMP until a certified EIR is available.
PROS AND CONS OF ALTERNATIVES:
Alternative 1 A) By resolution disapprove the CHWMP before 2/1/89, based on
the unavailability of a certified EIR.
B) Following the distribution of the-certified EIR reconsider
approval or disapproval of the CHWMP before 3/10/89.
Prc: Disapproving the CHWMP before 2/1/89 based on the unavailability
of the certified EIR allows the City to meet the Tanner Bill
deadlines and comply with CEQA guidelines for considering the plan.
Reconsidering the CHWMP after receiving the certified EIR and
before 3/10/89 will allow the City Council the opportunity to
evaluate the CHWMP within the timeline established by the County.
Con: Disapproving the CHWMP before 2/1/89 and reconsidering the plan
before 3/10/89 will require two separate Council actions.
Alternative 2 By resolution approve the CHWMP as is.
Pro: Following a review of the plan, Council can find that the plan meets
the intent of the Tanner Bill and local needs for dealing with the
management of hazardous waste. Approval at this time, along with
a majority of cities within the County will allow the City to meet
the submittal and approval timelines currently mandated by the
Tanner Bill.
Con: Approving the plan without considering a certified EIR could
invalidate the approval. It is unlikely that other cities will approve
the CHWMP without a certified EIR. I
7
city of San tins OBISpo
COUNCIL AGENDA REPORT
Alternative-3 By resolution disapprove the CHWMP and take no further action.
Pro: If the Council finds significant deficiencies in the CHWMP a
disapproval action is appropriate. Reasons for the disapproval can
be provided to initiate the desired changes.
Con: Disapproving the CHWMP will reduce the possibility of obtaining 51%
approval by other incorporated cities. Not having an approved
CHWMP will allow the State to establish the CHWMP guidelines
without local input.
Alternative 4 Take no action on the CHWMP until a certified EIR is available.
Pro: Taking no action on the CHWMP until a certified EIR is available
will require only one Council action. This action will meet the
requirements of the CEQA guidelines.
Con: Taking no action before 2/1/89 could be interpreted as approval of
the plan since the Tanner Bill considers no action on the plan to be
a vote of approval.
CITIZEN INPUT:
The Hazardous Waste Commission held public hearings on the plan at North,
Central, and Southern locations within the County. Very few persons commented on
�- the plan. In the case of the public hearing held within the City limits only four
citizens attended and no formal comment was made.
FISCAL IMPACT•
Approving the CHWMP will not have a direct fiscal impact. However, the T—Iner
Bill does require amending the General Plan and changing zoning ordinances. The
CHWMP's recommendation to implement a Household Hazardous Waste Collection
Program could have a fiscal impact of $40,000 per year on the City. State law
allows additional fees on solid-waste collection to offset the costs of household
hazardous waste collection.
I
CAO RECOMMENDATION:
A. By resolution disapprove the CHWMP.
B. Following distribution of the certified EIR, reconsider approval or disapproval
of the CHWMP before 3/10/89.
ATTACHMENTS•
Draft of Resolution Approving the Plan j
Draft Resolution Disapproving the Plan
Attachment #1 - City's Comments on Preliminary Review of the CHWMP
Attachment #2 - County Request for Time Extension
Attachment #3 - Executive Summary of CHWMP
Attachment #4 - Alternatives Recommended by the EIR
Figures 111.2 through 111.7 - The EIR Specified Areas for Hazardous Waste
Facilities
-- COPIES OF THE CHWMF WERE DISTRIBUTED TO C_O_U_NC_IL IN NOVEMBER. A COPY IS
ON FILE WITH THE CITY CLERK.
_V
C-�
Resolution No. (1989 Series)
A Resolution of the Council of the City of San Luis Obispo
Approving the Final Draft of the San Luis Obispo County Hazardous
Waste Management Plan (November, 1988)
WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis
Obispo to prepare a Hazardous Waste Management Plan and facility siting
procedures; and
WHEREAS, the County of San Luis Obispo with.input from the Waste Management
Commission has prepared a final draft of the County Hazardous Waste Management
Plan;and
WHEREAS, the.County of San Luis Obispo has also completed a draft Hazardous Waste
Management Plan Environmental Impact Report; and
WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority
of the cities within the county which.contain a majority of the population of the
incorporated areas before February 17, 1988; and
WHEREAS, if a city does not act within the 90 day time period, the ity will have been
deemed to approve the,plan; and
WHEREAS, the County of San Luis Obispo has requested approG of the County
Hazardous Waste Management.Plan.from incorporated cities within the county; and
WHEREAS, the City Council has reviewed, commented and forwarded questions to the
Waste Management Commission preliminary draft of the County Hazardous Waste
Management Plan;
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to:
1. Approve the final draft of the San Luis Obispo County Hazardous Waste
Management Plan (Nov. 1988) including:
a) goals, objectives and policies
b) plan implementation
Z Direct City Clerk to send a copy of this resolution as executed to:
G.B. Rowland, M.D., Health Agency Director
Department of Public Health
P.O. Box 1489
San Luis Obispo, CA 93406
On motion of seconded by
and on the following roll call vote:
AYES:
NOES:
A RSENTs
Resolution No. (1989 Series) continued:
the foregoing resolution was passed and adopted this day of
1989.
MAYOF. RON DUNIN
ATTEST:
.CITY CLERK PAM VOGES
APPROVED:
CITY A NISTRATIVE OFFICER
CITY ATTgORNEY
FIRE CI4IEF
Resolution No. (1989 Series)
A Resolution of the Council of the City of San Luis Obispo
Disapproving the Final Draft of the San Luis Obispo County
Hazardous Waste Management Plan (November, 1988)
WHEREAS, Chapter 1504 of the Government Code requires the County of San Luis
Obispo to prepare a Hazardous Waste Management Plan and facility siting
procedures; and
WHEREAS, the County of San Luis Obispo with input from the Waste.Management
Commission has prepared a final draft of the County Hazardous Waste Management
Plan; and
WHEREAS, the County of San Luis Obispo has also completed a draft Hazardous Waste
Management Plan Environmental Impact Report; and
WHEREAS, the County Hazardous Waste Management Plan shall be approved by a majority
of the cities within the county which contain a majority of the population of the
incorporated areas before February 17, 1988; and
WHEREAS, if a city does not act within the 90 day time period, the city will have been
deemed to approve the plan; and
WHEREAS, the County of San Luis Obispo has requested approval of the County
Hazardous Waste Management Plan from incorporated cities within the county; and
WHEREAS, the City Council has reviewed, commented and forwarded questions to the
Waste Management Commission preliminary draft of the County Hazardovi ;paste
Management Plan; and
WHEREAS, Section 15096 of the CE QA guidelines requires the City to consider an
Environmental document when considering the CHWMP.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo to:
1. Disapprove the final draft of the San Luis Obispo County Hazardous Waste
Management Plan (Nov. 1988) based on the following:
a) the EIR of the CHWMP is not complete and will not be available
until after 2/7/89.
b) State law requires action on the plan before 2/1/89. .
2. The City will reconsider the plan when a certified EIR is available.
3. Direct City Clerk to send a copy of this resolution as executed to:
G.B. Rowland, M.D., Health Agency Director
�. Department of Public Health
P.O. Boz 1489
San Luis Obispo, CA 93406
60 0
Resolution No. (1989 Series) continued
On motion of . seconded by
and on the following roll call vote:
AYES:
NOES:
ABSENT.
the foregoing resolution was passed and adopted this day of
. 1989.
MAYOR RON DUNIN
ATTEST:
CITY CLERK PAM VOGES
APPROVED:
CITY AD NISTRATIVE OFFICER
.
i
CITY AT70bRNEY
FIRE CHIEF
ATTV"ENT 1
aty0SA1 hAiS oBispo
Al,
990 Palm StreetlPost Office Box 8100 • San Luis Obispo. CA 93403-8100
June 21, 1988
TO: San Luis Obispo County Waste Management Commission
San Luis Obispo County Health Agency
FROM: John Dunn, City Administrative Officet(_�
SUBJECT: Draft Hazardous Waste Management Plan
With the enclosed letter I have sent my council's comments and questions concerning the
draft plan. City planning and Fire Department staff offer the following suggestions to
help you prepare a revised draft and a presentation to address the issues.
1. Why must the city or county have a hazardous waste plan? What are the consequences
if we do not have one?
The document should answer these questions at the beginning of the executive summary
and the beginning of Chapter 2.
Health risks and public concerns due to increased exposure to hazardous materials
warrant local government involvement. The state legislature (AB 2948) has defined a
role for cities and the county to address hazardous waste concerns. If the counL:_s
and their cities do not have a plan, then the state will regulate hazardous waste
facilities as local development requests are made. With state-approved local
hazardous waste plans, the cities and the county will have the greatest influence on
siting and development of hazardous-waste facilities.
2A. Must the plan have a map of potential hazardous-waste facility sites?
If the county, or a majority of the cities, decides to prepare a plan, "the plan
shall include _. an indentification of those hazardous waste facilities that can be
expanded to accommodate projected needs and an identification of general areas for
new hazardous waste facilities determined to be needed. In lieu of this facility and
area identification, the plan may instead include siting criteria to be utilized in
selecting sites for new hazardous waste facilities. If siting criteria are included
in the county hazardous waste management plan, the plan shall also designate general
areas where the criteria might be applicable." (Calif. Health & Safety Code
25135.1(d)(6))
Staff suggests that the plan explicitly state that disposal facilities will not be
needed within the county, and that the transfer facility likely to be needed should
be located in an industrial area.
Hazardous waste plan comments
Page 2
2B. The map and site discussion imply that the county has several places capable of
accommodating a hazardous waste facility.
The county does have remote, dry areas which have traditionally been seen as the best
places for waste disposal: The plan should distinguish between the types of
facilities in the map legends, and not lump transfer stations together with residual
repositories.
3. The plan is very complex; it should be simplified.
Like other state-mandated plans with specific content requirements, which address
complex subjects, complexity in the plan cannot be avoided. However, a simple,
direct writing style and separation of policy and background sections can help the
document appear less complex.
4. The plan seems to emphasize accommodation of projected waste amounts rather than
reducing hazardous wastes at the source.
In estimating capacity of waste facilities which may be needed, the plan assumes that
hazardous waste volumes will increase in proportion to projected population growth.
This seems a reasonable countywide assumption, in that much local waste is produced
by service business and households, not basic manufactu-ing. If basic manufacturing
increases at a higher rate, the capacity estimates would need to be revised.
Chapter 11 of the plan addresses waste reduction in households, existing businesses,
and new businesses. Several specific measures are prop_ ..u. Regulation of classes
chemicals and means to "close the loops" that hazardous materials follow are probably
most effectively conducted by governments which cover wider market areas --state and
federal.
5. The plan does not address saying "no."
The plan does say "no" to this county accommodating waste disposal from other
counties. Saying *no" to major industrial waste producers locally will not affect
the amount of waste generated, only the location, and is more properly a function of
local land-use plans and development review. Saying "no" to additional households
and service businesses is the essence of the growth issues being debated throughout
the county and the state. The main hazardous-material users in this area are power
plants and utilities, vineyards/farms, governments, colleges, hospitals, service
stations and auto repair/painting, commercial laundries and dry-cleaners,
photoprocessors, blueprinters, and press-printers, and household consumers.
6. The plan seems to emphasize economic feasibility rather than environmental
protection.
The goals of the plan demonstrate commitment to environmental quality, but the
discussion of implementation, logically, raises issues of economic feasibility. To
take an. extreme example, the most environmentally sound solution might be for each
hazardous-waste producer to completely recycle or render harmless its own wastes, but
each one cannot afford the required facilities under socially acceptable distribution
of costs. For example, each gas station cannot reprocess used motor oil, so some
environmental risks are entailed in temporary storage and transportation.
Hazardous waste plan comments
Page 3
(Some of the apparent "financial" bias of the plan could be eliminated simply by more
careful choice of words. City staff has pointed out several examples to county
staff, including page 1-24 second paragraph, last sentence, which would better read:
"From the operator's perspective, it may be cheaper for the small-quantity generator
to dispose of waste illegally than to pay the costs of proper disposal.")
7. Some of the siting criteria arc questionable, such as prohibiting waste disposal
sites ("repositories") only in "major aquifer recharge areas (page 9-6).
Staff agrees, and would note that 200 feet would not be much separation from an
active fault —the San Andreas? However, unless all hazardous wastes are to be
eliminated, it makes sense to identify the characteristics of those places which are
least likely to be harmed by disposal. Perhaps a better criterion would be exclusion
from any area where drainage contributes to surface water or groundwater used or
planned to be used for domestic water supply.
8. The plan should include a public education component.
Chapter 11 (pages 11-2 and 11-14 in particular) addresses public education,
9. How do we fund the plan? Will the state help pay for it?
C ' The county received a stategrant to prepare the plan. The plan identifies several
means to fund implementation (pages 16-13 and 16-16 in particular).
10. The plan is very technical; it's not practical to implement:
Progress has been. made in reducing waste production, keeping track of hazardous
materials, and cleaning up contaminated sites, mostly by federal and state efforts.
At times, the magnitude of the problem seems overwhelming, but staff is heartened by
efforts now compared to twenty years ago. As local governments review applications
for new businesses that handle hazardous materials, they can contract with
third-party experts, at applicant's expense, 'if they do not have staff expertise.
11. Further explanation of Chapter 16, Household Hazardous Waste, is required. People
need to be informed about hazards of household products are how to properly dispose
of wastes.
12. The estimates of present and future waste amounts are not consistent throughout the
report.
The discrepancies are due to different authors using different methods, which will be
resolved in the next draft.
13. This document is not what the Tanner Bill calls for.
The draft does follow state guidelines quite literally.
Hazardous waste plan comments
Page 4
14. If the city adopts standards for hazardous-waste industries which arc not met, what
are the the city's legal liabilities?
The city could be liable for its own facilities/actions in dealing with its own
wastes, regardless of the plan's standards. If the city approved something that
clearly contradicted its adopted policies, its decision could be reversed. If the
city failed to discover a hazardous condition caused by a private facility it would
not be liable. However, in most "worst-case" scenarios the city would be named in a
lawsuit and the city would incur significant defense costs.
15. The discussion of the emergency response plan gives an overly optimistic picture of
the county's and cities' ability to deal with hazardous material accidents.
Revise the discussion to indicate which agencies have not adopted the plan and the
lack of equipment/personnel available to deal with major accidents.
copies: M Dolder
M Multari
R. Picquet
gm2/haz-rsp
o -13
TACHMENT 2
County of San Luis Obispo
COUNTY GowitNMENT Ce;Tm - SAN LUIS OBISPO.CALIFORNIA 93408 - (805)549-5011
OFFICE OF THE
COUNTY ADM94MATOR
November 10, 1988
Alex R. Cunningham
Chief Deputy Director
State Department of Health.Services
714/744 'P' Street
Sacramento, CA 95814
Re: Submittal of San Luis Obispo County Hazardous Waste Management Plan
Dear Mr. Cunningham:
As you know, San Luis Obispo County's efforts toward completion of a County
Hazardous Waste Management Plan (CHWMP) began many months ago. We entered into
a contract with a consultant to prepare the required CEQA document last June.
The document was initiated in plenty of time to allow completion of the CEQA
process, even though state comments on the Draft CHWMP were over a week late.
Unfortunately, the Administrative Draft EIR was inadequate and required
substantial revisions. The EIR consultant's initial reluctance to complete the
revisions resulted in the need for lengthy negotiations and a substantial delay
in the process. This delay was absolutely necessary and unavoidable in order to
ensure the adequacy of the EIR, its subsequent certification and ultimate
approval of the CHWMP.
In an effort to make up a portion of the .lost time, the County has requested
that the State Clearinghouse grant a 30-day rather than 45-day EIR review
period. The request was denied, in part because of recommendations made to the
Office of Planning and Research by DOHS (see attached November 2 letter). While
we are disappointed that our request was denied, we understand the need for an
adequate level of review by the involved state agencies.
The County is making every effort to meet the extended deadlines for submittal
of the CHWMP. However, under present circumstances, it appears that the Final
EIR will not be available until late January. As a result, the Board of
Supervisors will not be able to consider and, hopefully, approve the plan until
j mid-February. The approved CHWMP will be submitted to your department
immediately thereafter.
Alex Cunningham
November 14, 1988 _
page 2
After the many months and thousands of dollars expended on this effort, it would
be unfortunate if circumstances beyond our control precluded state approval of
our plan. Any advice and assistance you can provide in addressing this problem
will help lead to successful completion of this major planning effort. I'm sure
that is a goal we both share. If you have any questions, please give me a call
at the above referenced number.
Thank you very much for your time.
Sincerely
Tim S. ess
Deputy County Administrator
cc: Board of Supervisors
Assemblyman Eric Seastrand
Senator Ken Maddy
Assemblywoman Sally Tanner
jh2/dohs/1
•. r.
AT-r'-WENT 3
CHAPTER 1
EXECUTIVE SUMMARY
CHAPTER 2 INTRODUCTION TO THE PLAN
This plan was developed by San Luis Obispo County in response to AB
2948 (Tanner, 1986), which authorizes the development of County
Hazardous Waste Management Plans (CHWMP). AB 2948 was enacted to
address the hazardous waste problems at the local level. The purpose of
AB 2948 and this plan is to:
-Reduce the generation of hazardous waste to the maximum extent
feasible;
*Provide the public, industry and local government with the
inform4ion needed to take rational steps to minimize, recycle, treat, .
dispose, and otherwise manage hazardous waste in California;
-Provide the basis for planning adequate hazardous waste management
facility capacity;
•Determine the current and estimated future hazardous waste
generation rates, project the need for facilities to manage this waste
and e, ablish a workable system to provide sites for needed facilities;
` -Insure that: Counties and Cities conduct local and regional efforts to
assess the needs for and plan for the establishment of local and
rec.::'-;;',,1a1 hazardous waste treatment and disposal facilities needed "to
manaae hazardous waste generated in their, jurisdiction;
•Insure that all local governments consider the feasibility and
appropriateness of identifying suitable general areas for treatment and
disposal facilities in their general plans..
Hazardous waste represents a potential threat because its chemical
characteristics can cause environmental damage if improperly treated,
stored, transported, or disposed. Hazardous waste is often produced as a
by-product of the manufacture of many of the goods which provide us with
the comforts and conveniences associated with modern society.
Households also generate hazardous waste, often in the form of used crank
case oil, and unused paints and pesticides.. Traditionally, hazardous waste
is disposed of in permitted hazardous waste landfills such as Casmalia.
However, due to changes in State and Federal regulations a disposal crisis
is imminent. New regulations call for a prohibition on the disposal of
untreated hazardous waste to landfills by the May 8, 1990. At this time,
there is a severe shortage of available treatment facilities in California.
This shortfall in treatment capacity could lead to an increase in illegal
1 - 1 — /�
I
disposal; and thus, an increase in the threat to public health and the
environment.
Approximately 6118.32 tons of hazardous waste was generated in San
Luis Obispo County in 1986. By the year 2000 this number could increase
to as much as 10,909.99 tons of hazardous waste yearly. These are large
enough volumes to cause concern but insufficient. to alone support the
typically sized hazardous waste management facility. San Luis Obispo
County does not generate enough hazardous waste to support any
of the seven generalized treatment facilities but the total
waste produced within the county for all treatment methods
may be sufficient to support the operation of a small-scale
transfer station. Such a transfer station could collect and temporarily
store hazardous waste prior to its shipment to other recycling or
treatment facilities. r local, small-scale transfer station might operate
as a collection center for local route service haulers serving local large
and small quantity generators and may be able to offer cost: savings to
local businesses and industries. A local transfer station might also serve
as a permanent collection center for household hazardous waste. Refer to
Chapter 7 for a discussion of facility needs.
Involvement and support from local residents and businesses are
crucial to the success of hazardous waste management in the future.
Through --planning efforts, such as this County Hazardous Waste
Management Plan, the public and local industry can become involved in the
hazardous waste management program. A partnership between :., local,
regional, and state government; and between the public and private sector
is necessary to overcome the threat to health and safety posed by
hazardous waste.
The County Hazardous .Waste Plan replaces the Hazardous Waste
Element contained in the County Solid Waste Management Plan. Eventually,
the Hazardous Waste Management Plan should be consistent with other
existing plans such as City and County General Plans, Air Pollution Control
District plans, Regional Water Quality Control Board Basin Plans and
County Solid Waste Management Plans (CoSWMP). There are likely to .be
obvious discrepancies batmeen the CHWMP and some of the other regional
and local plans. Provisions will have to made to settle these
discrepancies on a case by case basis. This may well necessitate
' Manifested = 3807.38 tons; SOG = 2027.94 tons; HHW = 283 tons. This does not
include possible residuals generation.
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amending other, plans. Some types of hazardous waste management
facilities, such as treatment or storage facilities, may be compatible
with industrial areas within cities. It would then become necessary for
local cities to make provisions for such facilities in existing city plans or
to outline the steps necessary to amend city plans to accommodate the
facilities in an implementation program as a part of the CHWMP.
Since the adoption of a Hazardous Waste Management Plan is an
exercise of discretionary judgment by affected local jurisdictions, an
Environmental Impact Report (EIR) will be prepared as part of the plan
review process. Public hearings will be held on both the Draft Plan and
the EIR so that local jurisdictions can consider public concerns and issues
arising from environmental review.
AB 2948 requires the establishment of an Advisory Committee :o serve
as a forum for public participation and to advise those local agencies
responsible for development of the plan The San Luis Obispo County Waste
Management Commission fulfills both the requirements of the County
Hazardous Waste Management Plan and the County Solid Waste Management
Plan.. The Commission holds regular public meetings and encourages public
participation.
CHAPTER 3 PURPOSE, GOALS, OBJECTIVES AND POLICIES
This chapter contains overall goals, objectives and polic;Pr. to guide
hazardous waste management in the County. In order to preserve ithe
quality of life and environmental integrity, now and for later generations;
it is necessary to develop a system to provide for the safe and effective
management of hazardous waste. It is the intent of this plan to strike a
balance between the needs of business and the overall requirement for a
healthy environment. As of November 1988, the Waste Management
Commission has been divided into two commissions: the Hazardous Waste
Management Commission and the Solid Waste Management Commission.
The Hazardous Waste Management Commission will continue as the
advisory commission for the completion of this Plan.
San Luis Obispo County currently exports most. of the hazardous waste
generated within its borders. It is the intent of this plan , to provrAe a
framework by which San Luis Obispo County can safely and effectively
take responsibility for its own hazardous waste.
The primary goal of this plan is to protect the public health, safety,
environment and maintain the economic viability of the county and the
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7
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state. This can be accomplished by ensuring that safe, effective and
economical hazardous waste management facilities are available when
they are needed, and that these facilities are of a type, and operated in a
manner, that protects public health and the environment. The plan uses
siting criteria to identify general areas within San Luis Obispo County
that may be suitable for hazardous waste treatment, storage and disposal
(TSD) facilities.
Waste management goals can also be accomplished by reducing the
volume of hazardous waste produced to the maximum extent feasible.
This effort will reduce the need for facilities. This plan emphasizes a
hierarchy of hazardous waste management techniques for existing and new
industries. The hierarchy emphasizes source reduction as the best
possible solution to the hazardous waste problem, with onsite recycling,
offsite recycling, onsite treatment, and offsite treatment as the second,
third, fourth, and fifth best options, respectively. For new and expanding
industries, the local planning and permit process should be used to ensure
that waste production is reduced to the maximum extent feasible.
Education will play a major role in improving hazardous waste
management. Both industry and the general public need.-,information to
take rational steps to minimize, recycle, treat, dispose, and otherwise
manage hazardous waste in San Luis Obispo County. Education can foster
the safe use and disposal of hazardous household products when no
alternatives are available. Education should also promote the use of
alternatives to hazardous household products.
Another goal is to discourage illegal disposal of hazardous waste. This
can be accomplished by providing economical and legal disposal options
for .industry and households, by monitoring hazardous waste generators to
insure proper disposal, and by enforcing existing laws and regulations.
Policy Statements
1 . New offsite hazardous waste management facilities shall be
primarily limited to a scale necessary to meet the hazardous waste
management needs of this county; larger facilities may be permitted in%
accordance with agreements reached between this county and other -
jurisdictions or upon determination of the local governing body that the
project meets local planning criteria and serves public needs.
The county and its cities recognize their collective responsibility to
cooperate with other governments in the region and the state in planning
1 -4 -
for the effective management of hazardous wastes generated in the region
C and the state in accordance with the hazardous waste management
hierarchy. Sound hazardous waste management planning, waste reduction
efforts, and appropriate facility siting are the mutual responsibility of all
governments. To this end, the county and its cities encourage multi-
county and regional efforts to plan and implement alternatives to land
disposal of untreated hazardous wastes and to limit the risks posed by the
transportation of hazardous wastes around the state. Agreements for new
facilities to provide the offsite capacity needed for hazardous waste
treatment and residuals disposal should be reached among jurisdictions
according to their fair share of the hazardous waste stream, each
jurisdiction's environmental suitability for different .types of facilities,
their economic interests, and the economic viability of different types
and sizes of facilities. Any privately-owned facility located in this
county shall be available to serve generators from inside and . ou4side .the
county.
"Fair share" denotes that each county is responsible for the disposition
of its own waste; that is, responsible for its: fair share of waste
management. No county should be expected to establish a hazardous waste
facility with a capacity exceeding the amount of waste they generate. A
county cannot be required to accept a facility , with a capacity that
exceeds the county's own needs, except as provided by an inter-
jurisdictional .agreement. It is recognized that the ,waste streams in each
county will probably not support an economically effiCie.nt hazardous
waste facility of each type needed to handle a county's .waste: Therefore,
counties are encouraged to enter into inter-jurisdictional agreements to
balance economic wastes generated.
2. a While accepting the fact that the entire spectrum of hazardous waste
management facilities are needed in California in order to ensure the
environmentally sound and economical disposal of hazardous waste, it
shall be the policy of San Luis Obispo County to establish a hierarchy for
preferred hazardous waste management systems within the County. The
.hierarchy is as follows:
A. Source reduction programs in local industry are to be actively
encouraged as the most preferred hazardous waste management
method;
B. Onsite recycling processes or systems in local industry are to be
actively encouraged as the second most preferred hazardous waste
management tec nology;
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C. Offsite recycling facilities, necessary to meet the current and
estimated future fair share needs of the County, are to be actively
encouraged and are the third most preferred hazardous waste
management facility applications;
D. Onsite treatment processes or systems established in local
industry are to be actively encouraged as the fourth most preferred
hazardous waste management technology;
E. Offsite treatment facilities, necessary to meet the current and
estimated future hazardous waste management facility fair share
needs of the County, are the fifth most preferred hazardous waste
management facility applications;
F. Hazardous waste disposal facilities, such as residuals repositories,
that are necessary to meet the current and estimated future hazardous
waste management facility fair share needs of the County, are the
least preferred hazardous waste management facility applications.
3 . San Luis Obispo County shall identify general areas that may be
suitable for hazardous waste management facilities sufficient to meet
the current and estimated future fair share needs of the County.
4. - San Luis Obispo County shall vigorously enforce hazardous•,.waste
management regulations in. order to discourage improper hazardous' waste
disposal practices.
5 . San Luis -Obispo County shall vigorously enforce existing regulations
pertaining to hazardous waste transportation, vehicular safety, and the
State manifest system regulations in order to ensure the safe
transportation of hazardous waste and material within San Luis Obispo
County.
6 . • San Luis Obispo County shall encourage and promote public education,
source reduction, and waste reduction efforts in order to reduce the need
for hazardous waste facilities within San Luis Obispo County.
7. All hazardous waste management facilities shall be required. to be
constructed in a manner that minimizes any threat to public health and
safety, and the environment.
8 . Collection and temporary storage facilities, such as those
recommended in the Household Hazardous Waste Chapter of this plan,
whose purpose is to provide alternatives to illegal disposal by households
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I
O and local industry and to preserve and maintain the environment, are to be
actively encouraged.
CHAPTER 4 CURRENT WASTE GENERATION
This chapter provides an analysis of current (1986) hazardous waste
generation in San Luis Obispo County in terms of type, amount and source
of generation. This analysis of current waste generation is compared with
the existing facilities within the county available to treat or dispose of
the waste generated. In 1986 San Luis Obispo generated an estimated
6118.32 tons of hazardous waste: Manifested waste= 3807.38 tons; waste
from small quantity generators = 2027.94 tons; waste from households
283 tons (the number of significant figures have been retained for
calculation purposes only and are not meant to reflect the accuracy of the
methodology). All of this waste was disposed of outside of San Luis
Obispo County except for 281 tons of asbestos-containing Waste, which
was disposed of at Cold Canyon, a Class III landfill. Cold Canyon Landfill
also accepted 83 tons of asbestos-containing waste from other counties.
With the exception of the County Agricultural Commission, which. has a
small storage/transfer` facility for waste household pesticides, San Luis
Obispo County has no commercial storage or treatment facilities.
However, several local ,industries do treat their own waste onsite. These
Cindustries include Calzyme Laboratories, Chemron, CTS Electronics, P.G.
and E. Diablo Canyon, P.G.. and E. Morro Bay, and Sunbank Electronics.
urthermore, asbestos-containing waste is generally stabilized (i.e.,
trPated) onsite prior, to shipping.
CHAPTER 5 PROJECTED WASTE GENERATION
This chapter provides rough estimates of hazardous waste generation
in the year 2000. The total amount of hazardous waste generated by the
year 2000 is estimated to be as much as 10,909.99 tons: projected
industrial waste = 4557.47 tons, projected small quantity generator
waste = 2554.2 tons, projected cleanup waste 3371.8 tons, projected new
wastes = .82, and projected household waste of 425.7 tons. (This
projection does not include estimates of the volumes of residuals that
would be generated by the treatment of these volumes of hazardous
waste.) All projections assume that waste generation increases will be
proportional to the expected county population growth rates.
CHAPTER 6 TSDF SHORTFALL
This chapter reviews current and projected waste generation estimates
from Chapter Four and Five in terms of demand for treatment and disposal
Ucapacity. The current (1986) total amount of hazardous waste requiring
treatment or disposal is estimated to be approximately 671.7.37 tons This
number is based on an estimated waste generation rate of 6118.32 plus
966.86 tons of estimated residuals and less 367.81 tons of existing
treatment capacity, (i.e., the onsite stabilization of asbestos-containing
waste).
CURRENT(1986) S.L.O. COUNTY COMMERCIAL HAZARDOUS WASTE
TREATMENT/DISPOSAL FACILITIES SHORTFALL
Generalized Treatment Method Current Countyy Facility Needs(tons)
1 . Aqueous Treatment-Organic 49.66
2. Aqueous Treatment-Metals/Neutralization 179.19
3. Incineration 1746.65
4. Solvent Recovery 223.12
5. Oil Recovery 2858.91
6. Other Recycling 628.03
7. Stabilization 64.95
Stabilization (Asbestos-Containing Waste) 0.00
Residuals Disposal:
Class 1 963.57
Class III: Asbestos-containing waste 3.29
TOTAL 6717.37
The total amount of hazardous wash requiring treatment or disposal
by the year 2000 is estimated to be as m--^,h as 12,626.15 tons per year.
PROJECTED S.L.O. COUNTY COMMERCIAL HAZARDOUS WASTE
TREATMENT/DISPOSAL FACILITIES SHORTFALL
Projected County Treatment or Disposal
Generalized Treatment Method Shortfall in the Year 2000 (Tons/Year)
1 Aqueous Treatment-Organic 74.99
2 Aqueous Treatment-Metals/Neutralization 191 .93
3 Incineration 4695.57
4 Solvent Recovery 346.30
5 oil Recovery 4528.19
6 Other Recycling 515.50
7 Stabilization 140.19
Stabilization: Asbestos-Containing Waste
Residuals Disposal:
Class 1 1.716.16
Class III: Asbestos_Containing Waste 417.32
TOTAL 12,626.15 tons/year
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CHAPTER 7 FACILITIES
This chapter contains summaries of the County's current and projected
hazardous waste generation, shows the distribution of large quantity
generators among the cities, and outlines the hazardous waste facility
needs of the county to manage the waste produced in the county.
It is estimated that San Luis Obispo County currently produces about
6118.32 tons of hazardous waste. In the year 2000, this figure may
increase to as high as 10,909.99 tons. The projection estimate assumes
that current waste figures will increase proportionately with population
increases.
While San Luis Obispo County does produce small amounts of many .of
the different types of hazardous waste, the county does ,,ot generate
enough hazardous waste on its own to support any of the seven general
types of treatment facilities. However, the total waste produced within
the county may be sufficient to support the operation of a small-scale
transfer station. Such a transfer station. could collect and temporarily
store hazardous waste prior to their shipment to other recycling or
treatment facilities. A small-scale transfer station might operate as a
collection center for route service haulers serving local large and small
quantity generators. This may offer cost savings for the management of
hazardous waste produced by local businesses and ind,�,r', ries. A local
transfer station might also,. serve as .a permanent collection center for
household hazardous waste.
CHAPTER 8 WASTE REDUCTION
This chapter introduces and explains the elements of waste reduction,
defines the current and projected local waste . reduction potential,
describes the barriers to waste reduction and identifies goals, objectives,
policies, and programs for waste reduction. There , are three methods of
waste reduction: source reduction, onsite recycling, and onsite treatment.
Source reduction includes those changes implemented during the
manufacturing process which reduce the amount or toxicity of hazardous
material used or waste generated. This is the preferred method of waste
reduction. Onsite recycling refers to the reuse of waste/material by the
generator and/or user or those waste/material at the location of their
generation/use. Onsite treatment methods, while encouraged, are the
least desirable method of waste reduction. There are four basic types of
aqueous treatment - organic, metals/neutralization, incineration, and
1 -9 /w
stabilization. These methods of treatment vary in their ability to actually
reduce the amount of waste generated.
Waste reduction is desirable because it reduces the need for the
transportation and offsite management of hazardous waste. The barriers
to waste reduction include educational barriers, technical barriers,
financial barriers, governmental barriers, managerial barriers, and
physical barriers. The amount of waste manifested in. San Luis. Obispo
County was down 50% in 1986 from the previous year due in part to waste
reduction efforts by local industries. The following goals, objectives,
policies and programs are designed to encourage additional waste
reduction efforts:
Waste Reduction Goals
1 . Reduce the use of hazardous substances and the 'generation of
hazardous waste from all sources.
2. Recover and recycle, where practical, the remaining hazardous
waste for reuse.
3. Treat that hazardous waste not amenable to source reduction or
recycling as close to the source as possible so that the environment
and community health are not threatened by their ultimate release. or _
disposal.
i
4. Educate and advise local industries on how they can take the
necessary steps to reduce their hazardous waste streams.
5. Encourage local governments to assist local industry,, in their
environmentally sound, waste reduction efforts, and encourage local .
government to participate as well.
Waste Reduction Objectives
1. Establish an effective system of flexible, financially feasible,
environmentally sound programs for the reduction of hazardous waste
generated;
2. Develop and implement an educational program that will accomplish
the following:
-Promote understanding among industry regarding the benefits of
waste reduction, and the legal and environmental ,con"sequences of
improper hazardous waste management;
-Encourage the public and local governments. to support
environmentally sound waste reduction efforts;
-Provide useful information regarding waste reduction technology
and available resources on an industry specific basis;
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�-� 3. Gain the cooperation of every industry in San Luis Obispo County in
the area of waste reduction by the year 2000;
4. Have trained personnel perform regular onsite inspections and
waste reduction consultations;
5. Develop and provide an information and referral service for waste
reduction information;
6. Achieve a 5-10% decrease of the County's reducible hazardous
waste stream by the year 2000.
Waste Reduction Policies
1 . San Luis Obispo County shall promote efforts to reduce the use of
hazardous substances and the generation of hazardous waste from all
sources.
2. San Luis Obispo County shall encourage the recovery and recycling 'of
the remaining hazardous waste for reuse wherever safe and practical.
3. San Luis Obispo County shall encourage the .treatment of that
hazardous waste not amenable to source reduction or recycling as close
to the source as possible so that the environment and community health .
are 'not threatened by their ultimate release or disposal:
4. San Luis Obispo County shall encourage and promote the development
of waste reduction education programs for industry, local governments,
and the general public.
Waste reduction Programs
1 . &aroements to Cooperate: In order to measure interest levels,
Agreements to Cooperate with future waste reduction programs should
be obtained from local industries as a- first step in implementing a
local waste reduction plan.
2. Consultation Program for Existing Generators: In order to overcome
the educational barriers to waste reduction, waste reduction
information should be provided to existing hazardous waste generators.
3. Plan Check Program of New Generators: In order to minimize future
waste generation and assist new businesses in their waste reduction
efforts, the building plans of future generators should be inspected for
waste reduction opportunities and programs.
4. Awards_ Program for Outstandino Hazardous Waste Management
ff r : The awards program would give public recognition to those
companies who have shown awareness, commitment and success in
their individual waste reduction programs, and in doing so provide an
opportunity for waste reduction education.
--
Waste Reduction Potential
Using DOHS methodology, it is estimated that the current waste stream
(1986) could be reduced by approximately 306.21 tons or 8% (of the
reducible waste stream), and the projected waste stream could be reduced
by approximately 47263 tons or 8% (of the reducible waste stream).
These are very rough estimates of waste reduction potential.
CHAPTER 9 SITING
This chapter describes the different types of hazardous waste
facilities, the criteria or standards to be used for siting those facilities,
general areas within the county where the criteria might apply, and siting
recommendations, goals, and policies. There are three basic types of
hazardous waste facilities discussed in this chapter:
1 . Transfer and Storage Facilities,
2. Treatment Facilities, (e.g. Solidification, Stabilization, Incineration
and Recycling)
3. Residuals Repositories for Treated Residues.
Criteria
The criteria which apply to all hazardous waste facilities include those
related to:
High Hazard Areas (areas where human or animal life could be jeopardized
if fugitive releases occur), i.e., s.:lsmic, floodplains, wetlands, habitat of.. .
endangered species, unstable salt; major 'recharge areas` for aquifers;
Public Safety (criteria designed to protect the general public), i.e.,
distance from residences, distance from immobile populations, proximity
to major transportation routes;
Physical Limitations of the Site Area (areas which, because of their
existing physical characteristics, must be utilized in specified ways), i.e.,
permeable strata and soils, nonattainment air areas, PSD air areas; and
Location-Specific Criteria (these are criteria which could affect the
location of the sites, but are not necessarily site-specific), i.e., proximity
to public facilities, proximity to wasie generation stream, industrial,
commercial and specially-zoned lands, recreational, cultural, or aesthetic
areas, mineral resources areas, military lands, other State, Federal and
Indian lands.
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The individual criteria are divided into those that pertain to all
facilities (treatment, transfer . and residuals repository); criteria specific
to treatment and transfer facilities; and criteria which apply only to
residuals repositories. The criteria should be used in conjunction with
the policies of this chapter when evaluating applications for hazardous
waste treatment, storage and disposal facilities.
Identification of General Areas
The overall intent in identifying general areas is to verify that after
applying the policies and siting criteria, there remained areas in the
county that could be used to site hazardous waste facilities as required by
the guidelines. Maps were prepared only for the purpose of demonstrating
that the siting criteria did not unreasonably eliminate all lands in the
county. As a result of the mapping, three general areas were identified
where the siting criteria may be applicable for a repository facility.
General areas for other facilities were also available based on the siting
criteria. Areas in both the north, central and south county were found to
be available for all facilities based on siting criteria.
Conclusions .
° San Luis Obispo County has sufficient acreage and zoning :o site
needed commercial offsite hazardous waste transfer/storage, and
C; treatment facilities within existing commercial and industrial areas.
° General areas where facilities may be located are provided in .Figure
9-1 . Additional screening is required utilizing County General Plan ,
criteria, risk assessment maps and site specific reports if any general
area is to be considered a possible site for hazardous waste facilities.
.° San Luis Obispo County has limited areas for residuals repositories.
While preliminary siting analyses identified several general areas, many
were eliminated as not appropriate based on evaluation under the
specified criteria. The remaining general areas will require further
extensive environmental review and site specific investigation before a
potential site could be developed and permitted.
Recommendations
The criteria should be used in conjunction with the following policies
to review proposed facilities in the county:
° Revise county Land Use Element and Ordinance and City Zoning
Ordinances, when necessary, , to ensure proper zoning and zoning
consistency for hazardous waste facilities.
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° Commercial offsite transfer/treatment facilities should be located
in industrial zones. Residual repositories should be located in a Public
Facility Land Use Category or equivalent zones.
° Develop and include requirements for waste reduction, as
appropriate, to be included in Conditions of Approval for hazardous
waste generators.
Goals
1 . To establish an efficient siting and permitting process that provides
for needed facilities in the county and includes extensive public input to
aid in selecting sites.
2. To ensure safe and responsible management of hazardous waste by
providing for facilities that effectively manage the hazardous waste
produced in the county, providing for hazardous waste facilities to
encourage legal disposal of waste, and by reducing the use of outmoded
disposal practices.
3. To provide an effective monitoring system _ of hazardous waste
facilities and to provide effective enforcement of federal, state, and
county hazardous waste regulations. These mechanisms are necessary to
ensure that public health and the environment, as well as economic
vitality, are protected.
4. To establish uniform siting criteria for evaluating potential sites
for hazardous waste facilities so as to assure that facilities are proposed
in suitable areas and to focus discussion about 'proposed sites on those
factors that are pertinent and critical to the siting process.
Policy Statement
New offsite hazardous waste management facilities shall be primarily
limited to a scale necessary to meet the hazardous waste management
needs of this county; larger facilities may be permitted in accordance
with agreements reached between this county and other jurisdictions or
upon determination of the local governing body that the project meets
local planning criteria and serves public needs.
The county and its cities recognize their collective responsibility to
cooperate with other governments in the region and the state in planning
for the effective management of hazardous wastes generated in the region
and the state in accordance with the hazardous waste management
hierarchy. Sound hazardous waste management planning, waste reduction
efforts, and appropriate facility siting are the mutual responsibility of all
governments. To this end, the county and its cities encourage multi-
county and regional efforts to plan and implement alternatives to land 1
1 - 14
disposal of untreated hazardous wastes and to limit the risks posed by the
transportation of hazardous wastes around the state. Agreements for new
facilities to provide the offsite capacity needed for hazardous waste
treatment and residuals disposal should be reached among jurisdictions
according to their fair share of the hazardous waste stream, each
jurisdiction's environmental suitability for different types of facilities,
their economic interests, and the economic viability of different types
and sizes of facilities. Any privately-owned facility located in this
county shall be available to serve generators from inside and outside the
county.
"Fair share" denotes that each county is responsible for the disposition
of its own waste; that is, responsible for its fair share of waste
management. No county should be expected to establish a hazardous waste
facility with a cape-_.,ity exceeding the amount of waste they generate. A
county cannot be required to accept a facility with a capacity that
exceeds the county's own needs, except as provided by ,an inter-
jurisdictional agreement. It is recognized that the waste streams in each
county will probably not support an economically efficient hazardous
waste facility of each type needed to handle a county's waste. Therefore,
counties are e:icc-+raged to enter into inter-jurisdictional agreements to
balance economic efficiency in the size of facilities and to responsibly
handle their fair share of the waste generated.
Policies
1 . Siting Consistency: The county, and each city, shall require that all
local land use decisions on siting specified hazardous waste management
facilities are consistent with the goals and policies and the siting
criteria contained in the County Hazardous Waste Management Plan.
2. Focus of Inter-Jurisdictional Agreement Negotiations: The county
shall enter into discussions with other jurisdictions for the purpose of
negotiating one or more inter-jurisdictional agreements for the siting of
hazardous waste management facilities adequate and necessary to meet
the needs of the signatory jurisdictions. Such agreements shall follow
the principle of fair phare and may take into account both the volumes and
degree of hazard for the wastes generated that require offsite
management within each participating jurisdiction, and the degree or
waste reduction effort made by each participating jurisdiction.
If the siting of a particular type of hazardous waste management
facility needed in this county is not environmentally appropriate or
1 -15
-a 3
economically viable, the county shall seek to reach an agreement with one
or more other. jurisdictions to facilitate the siting of a larger,
environmentally appropriate and economically viable facility (or
facilities) to be located elsewhere. This county and its cities, in turn,
agree to actively consider and, if appropriate, to commit as part of an
inter-jurisdictional agreement to approve the siting of an environmentally
appropriate facility (or facilities) within its own borders designed and
sized to serve the hazardous waste management needs of other
jurisdictions as well as of this county.
3. The adopted siting criteria should take precedence over the general
areas designated on the CHWMP map. The map is an approximation only and
was developed to test the applicability of the siting criteria in San Luis
Obispo County.
4. The siting criteria shall be used to determine the location of new or
expanded hazardous waste facilities in the county. The criteria, along
with the requirements of policies identified in this plan, represent
development standards which shall be met before approval of a particular
facility.
5. A risk assessment shall be required for any application proposing
hazardous waste facilities for the purpose of estimating the level of risk
to human health and the environment. Sufficient detail should be provided
so that decision-makers vJil have an adequate basis from which to
consider alternatives. I he risk assessment shall include, but not be
limited to, the followingitems:
• the use of the worst case scenario;
• the identification of the maximum volumes expected of different
classes (or types) of hazardous materials or waste;
• the identification of the physical and chemical characteristics of
the waste that will be handled;
• a discussion of the size and composition of any residential or
populated areas nearby and the potential for impacting these areas;
• an evaluation of the. potential impacts to air quality, water
resources, vegetation and :•:''•dlife;
• an evaluation of the project's effect on immobile populations;
• the analyses of emergency, response capabilities;
• the evaluation of different transportation options; and
• a discussion of the design of the facility with regard to protection
of the human health and the environment.
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T �
6. The amount of land necessary to accommodate a hazardous waste
facility should be determined based on a thorough assessment of risk to
public health and safety. The land areas specified for the different types
of facilities in the DOHS Guidelines should only be used as a guide (Table
Three of Chapter 7).
7. Hazardous waste mana9ement facilities, other than residuals
repositories, are basically facilities which, for the most part, are
compatible with industrial uses. These facilities may be sited in
industrial and commercial zones subject to the approval of a conditional
use permit if found to be compatible with the existing permitted uses and
if the siting criteria have been. met. These facilities may not, however, be
appropriate for light commercially-zoned areas. J
8. Residuals repositories require large land areas; thus, it is not
practical or economical to site them in industrial and commercial zones.
Since these facilities are long-term uses of land, they: are better. suited to
being located in rural areas in an appropriate zone.
9. Department of Defense military land shall not be considered for the
establishment of multi-user, offsite, hazardous waste facilities.
10. The siting criteria shall be used in determining the suitability of
lands within state and federal lands.
11 . Residuals repositories can have self-sufficient services, succi ^s
Je
water and septic systems and emergency services. Any proposal fcr a
residuals repository must identify the demand for water, sewage disposal
and utility systems, discuss the design of these systems and discuss the
type of conservation measures incorporated in the project design. In
addition, the water, sewage disposal and utility systems shall be designed
with regard for the protection of significant environmental resources.
12. All hazardous waste facilities shall comply with APCD rules and
regulations and be consistent with the Air Quality Attainment Plan.
13. Applications for hazardous waste facilities shall include an
assessment of the project's impact on air quality, including an analyses of
whether emissions from the facility would significantly contribute to the
nonattainment of standards, consideration of mitigation measures and
provide an analyses of the projected emissions associated with -:he
transport of materials out of the county.
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14. Architectural and visual analyses shall be required when siting -�
facilities to protect views and vistas, ridgelines, coastlines, etc.
Architectural review criteria shall be applicable to all proposed
facilities.
CHAPTER 10 TRANSPORTATION
This chapter discusses legislation concerning hazardous waste
transport and the adequacy of the existing hazardous waste transportation
system in the County. This chapter contains goals and policies to be used
as starting points for local jurisdictions to consider when selecting
connector routes between proposed treatment, storage and disposal (TSD)
facilities and the major transportation routes in the region. The intent of
these policies is to provide rules that facility developers will have to
comply with when considering general areas for development. The
designation of preferred routes should be part of the project review
process for facility applications.
Sections 31304 and 31305 of the California Vehicle Code, which
became effective on January 1 , 1987, describe the limits on the authority
of cities and counties to restrict or prohibit transportation of hazardous
waste or material on specified highways under local control. The local
jurisdiction must meet the following requirements:
1 ) It must be demonstrated that the restricted or prohibited route is
less safe than a reasonable alternative route;
2) The restriction or prohibition must not be precluded by federal law;
3) The restriction or prohibition must not eliminate necessary access
to local pickup or delivery consistent with safe vehicular operation; or
does not restrict or prohibit when no other lawful alternative exists;
4) Surrounding jurisdictions must concur, in writing, that the
restrictions or prohibitions do not interfere with through
transportation.
The California Highway Patrol may preempt any local restriction that
is incompatible with reasonable and necessary access. Adversely affected
motor carriers may appeal local restrictions to the California Highway
Patrol.
Transportation Goals
To ensure the safe transportation of hazardous waste from the source
of generation to the point of ultimate disposal.
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To ensure that existing hazardous waste transportation laws and
C, regulations are vigorously enforced in order to protect the public health
and safety and environmental integrity of San Luis Obispo County, and
California.
Transportation Objectives
1) To provide hazardous waste transportation guidelines for local
generators in order to protect the public health and. safety.
2) To provide potential applicants for treatment, storage and disposal
facility permits with policies that must be complied with when
considering general areas for development.
Transportation Policies
Any educational program, undertaken by an operator or potential
operator of a hazardous waste treatment,. storage or disposal facility,
must include information on transportation regulations, -requirements, and
local policies.
San Luis Obispo County . shall encourage and promote onsite ,treatment
and recycling in order to reduce the volumes of hazardous waste that must
be transported.
CWhenever possible, routes connecting hazardous waste treatment,
storage or disposal (TSD) facilities and major state 'and' federal highways
shall:
a) be by the shortt�st available route that its consistent with other
policies;
b) shall not pass by schools or institutions with a non-mobile
population such as hospitals and the like;
c) Operators of milkruns for the collection of hazardous waste from
local generators shall only use designated truck transportation routes
and shall not use residential or neighborhood streets unless those
minor roadways provide the only reasonable access to the generator.
Applicants for hazardous waste treatment, storage or disposal (TSD)
facilities shall prepare a transportation and safety plan, as part of the
land use application proce-s, outlining safety feature.5 and procedures to
be used by the facility operator and hazardous waste- haulers to protect
the public during the 'transportation process.
Applicants shall undertake all studies necessary to determine the
impact on the local .and regional transportation system caused by the
transportation of hazardous materials to the proposed TSD facility.
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(� -a s
Applicants for TSD facilities may be responsible for all transportation
improvements necessary to mitigate the impacts caused by the
transportation of hazardous materials to the facility.
CHAPTER 11 IMPLEMENTATION
This chapter summarizes the activities and programs necessary to
begin the development of a system for hazardous waste management in
San Luis Obispo County. In general terms, the following are necessary to
ensure the proper management of hazardous waste:
• educate the general public and local industries by gathering and
distributing information about hazardous waste;
• develop proper disposal options for household hazardous waste;
• reduce the volumes and toxicity of the hazardous waste produced;
• provide proper locations for new or expanding industries that use
hazardous material or generate hazardous waste; and
• insure that new industries implement feasible waste reduction
measures and disposal options.
In addition to these activities city and county General Plans, Zoning
Ordinances, and Discretionary Permit application processes need to be
modified prior to CHWMP adoption in order to implement the CHWMP. The
following are some suggested implementation measures whose intent is
to ensure compatibility of land uses and to protect residential uses from
risks due to unnecessary exposure to hazardous material and waste.
Adopt local ordinances that incorporate siting criteria for
application to existing industries. Some industries that generate
hazardous waste or handle hazardous materials may be located in
inappropriate locations. These industries may. be considered "non-
conforming uses."
Incorporate siting criteria for offsite treatment, storage, and
disposal facilities and develop guidelines that identify the content
requirements of hazardous waste facility applications, outline the
permit process and discuss the environmental review process for these
facilities.
° Modify the permitted uses allowed under thehome occupation
category. Some types of "home occupations" such as pest control
operations, pool chemical suppliers, furniture stripping and the like,
may be inappropriate in residential areas because these occupations
may involve storage of large quantities of dangerous types of hazardous
material in close proximity to residences.
r-.
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Changes to administrative .procedures for project review and
amendments to zoning ordinances and general plans should be
accomplished within 180 days after after DOHS approval of the CHWMP.
Existing Inspection, Technical Assistance, and Enforcement
Activities
At the present time each of the following local agencies is involved
with either inspection, technical assistance, or enforcement activities
associated with the regulation of hazardous waste and/or material within
San Luis Obispo County:
- San Luis Obispo County Health Department, Environmental Health
Division
= San Luis Obispo City Fire Department
- SarL Luis Obispo City Public Works Department; Wastewater
Treatment Control
San Luis Obispo County Agricultural Commissioner
Airi Pollution Control District
Recommendations for Inspection, Technical Assistance, ;and
Enforcement Activities
C ) The inspection and enforcement activities of the various local agencies
should be coordinated and integrated in order to better serve the public
and industry, and to make it easier for each agency to -accomp.lish its
regulatory. requirements.
1 . Establish .review early in the project planning process by all
affected agencies
2. Review new projects that involve the storage of hazardous
materials or the generation of hazardous waste.
S. Final inspections of the project should be coordinated with
Environmental Health staff and the Building and Fire Departments.
Approval Process for Hazardous Waste Management Plans
° Approval process for the CHWMP requires the approval of the Board of
Supervisors and the majority of the cities with a majority of the
population.
° Thee draft plan was submitted to the Department of Health Services
by March 31 , 1988. It was returned with comments on July 7, 1988.
° Public hearings on the draft plan were held by the Board of
Supervisors, the city councils of six of the seven incorporated cities,
and the Waste Management Commission.
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° The final approved CHWMP is due to the Department of Health
Services by February 1 , 1989.
SB 477, (Greene, 1987)
SB 477 (Greene,1987) deletes the identification of specific sites for
new facilities and relies instead on the identification of general areas for
hazardous waste management facilities. SB 477 extends the deadline
from 90 to 180 days for the adoption of local ordinances that require that
land use decisions be consistent with the portions of the plan which
identify general areas or siting criteria for hazardous waste facilities.
SB 477 also allows individual cities to adopt more stringent planning
requirements or siting criteria than those specified in the County Plan, so
long as they are reasonable and non-exclusionary.
The Local Assessment Committee ` (LAC) and the Evaluation .f
TSDF Applications
The LAC is charged with determining whether, and under what
conditions, the particular TSDF application is consistent with the CHWtviP
and acceptable to local land use decision-making authorities.
Within 90 days after receiving notification of the filing of a notice of
intent by the facility applicant, the legislative body of the affect-.-d
jurisdiction shall appoint a seven member LAC. The membership .of the
LAC shall be broadly constituted to reflect the makeup of the community,
and shall include three representative of the community at large, two
representative of environmental or community interest groups and two
representatives of affected businesses or industries. Members of the LAC
shall have no direct interest in the proposed specified hazardous waste
facility project.
CHAPTER 12 EMERGENCY RESPONSE
This chapter provides an overview of the existing San Luis Obispo
County Hazardous Materials Emergency Response (ER) Plan and the
accompanying Countywide Resource List. for emergency response. This
chapter also contains recommendations for additional local measures that
may be necessary in the event that hazardous waste treatment, storage
and disposal (TSD) facilities are actually constructed in the county.
Overview of County Emergency Response Plan
This plan was developed by the San Luis Obispo County Office of
Emergency Services and adopted by San Luis Obispo County in July of 1985.
The Hazardous Materials Emergency Response Plan (ERP), (Appendix 13-1)
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and the accompanying Countywide Resource List (Appendix 13-2) are for
use by local agencies and the private sector in the event of a hazardous
materials or waste emergency in the unincorporated areas of the county.
The purpose of the ERP is to establish the County's response organization,
command authority, responsibilities, functions and inter-actions required
to mitigate hazardous materials emergencies in the unincorporated areas
of the county. The ERP identifies areas of local, state and federal
responsibility to minimize damage to human health, natural systems, and
property caused by the release of hazardous materials. Local
responsibilities are principally focused on discovery, notification,
evaluation, initiation of immediate protective actions, and monitoring of
recovery operations.
Hazard Assessment
San Luis Obispo County, a+pile generally rural and without .large
industrial complexes does contain major north/south transportation
arteries, such as US 101 and Southern Pacific Railroad, each transporting
hundreds of thousands of tons of hazardous materials through sand into the
county each year. The county is highly exposed to the effects of a major
catastrophic emergency due to the proximity of US 101 and the railroad to
densely populated areas of the county. In addition, the major east/west
traffic routes of the county, Highways 41 , 46 and 166 are used for a
C smaller volume of traffic but over a more hazardous route. US 101 and
Highways 46 and 166 are :aed for a large volume of transportation ' of
hazardous waste because of the statewide dependence on the Casmalia and
Kettleman Hills hazardous via.+..e landfills.
For incidents completely outside the jurisdiction of the ER Plan, i.e.,
within the incorporated cities, the IC authority resides with the
individual jurisdiction. The responding personnel may be limited to city
police and fire departments augmented by other city police and fire
departments with whom the individual city has mutual aid agreements.
Recommendations
The County ER Plan has been adopted by the County and in a modified
form by the City of San Luis Obispo; but not by the other incorporated
cities within the county. There are mutual aid agreements in force among
the police and fire departments.
It is recommended that these cities that have not adopted an ER Plan
consider using the County ER Plan as a model, and enter into countywide
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mutual aid agreements on a broader basis in order to ensure emergency
response capabilities within all local jurisdictions.
Suggested Policy Statement
The following suggested policy statement is intended to ensure that
local emergency response capabilities are improved as new facilities are
established:
All treatment, storage and disposal facilities should supply to the
nearest local response agency, such as the local Fire Department, all the
necessary equipment and training for emergency response that becomes
necessary due to the operation of the facility.
CHAPTER 13 STORAGE REGULATIONS
This chapter presents a brief discussion of storage regulations and
their implementation in San Luis Obispo County.
Proper storage of waste is an integral part of safe and responsible
management of hazardous waste. Several different agencies regulate
storage, depending on the type of storage method used and the
characteristics of the hazardous substance stored. In many cases,
regulations corer both hazardous material and hazardous waste. The
intent of storage regulations is to prevent the contamination of the -
environment by release of hazardous waste. or material into the air,
water, or soil.
Regulations
Regulations and programs for hazardous waste/material storage can be
separated into three general categories:
Regulations and programs for underground tanks;
•Regulations for all methods of storage under the Full Disclosure Law;
-Regulations which place time limitations on storage of hazardous
Existing Programs for Hazardous Waste and Materials Storage
*Underground Tanks
Both the Eng.i►onmental Health Division (EHD) of the San Luis Obispo
County Health Agency and the San Luis Obispo Fire Department (for tanks
within the City of San Luis Obispo) require permits to be issued for
underground hazardous materials storage tanks. Permits are required to
abandon an underground tank. Both of these agencies submit monthly site
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J,
mitigation reports on the status of leaking underground storage tanks to
the Regional Water Quality Control Board (RWQCB).
The underground tank program is supported through the use of fees
applied to the businesses and industries that use underground tanks. The
fee is based on the number of tanks used by the business.
•Full Disclosure Law
The EHD is the administering agency for the implementation of the Full
Disclosure Law, AB 2185/2187 (Waters, 1985,87), for the entire county,
except for within the city limits of San Luis Obispo where the City Fire
Department is the responsible agency. Inspections will be conducted by
the Hazardous Materials Specialists currently responsible for . the
underground tank program andfor incident response to hazardous
materials or waste emergencies. Additionally, as provided by AB 2185/87
(Waters, 1985,87); the County Department of Agriculture wilkbe
accepting hazardous materials inventories, conducting site, inspections
..and forwarding--the information to the County Health Department, .Division.
of Environmental Health. A Memorandum of Regulatory Authority is' in
process. The costs of implementing the Full Disclosure Law are recovered
through the use of plan review fees that are based on the number, and
volume of chemicals a business handles. There is no general fund support
for this program.
The information collected through .the AB 2185/2187 (Waters,
1985,87) program-,will be made available to those agencies responsible
for reacting to a hazardous materials or waste emergency. Businesses
will be required to keep a copy of their complete Business Plans, including
emergency response procedures, onsite and available for use at all times.
The public may request in writing certain information about .a facility.
The record for the facility will be reviewed by the EHD for trade secrets
or other proprietary information. If appropriate, EHD will release the
requested information. There will be no direct access to files or
computer records by the general public.
Certain categories of industry offer the greatest , potential for waste
minimization-.methods and represent the greater threat of incidents from
improper storage and handling of hazardous materials and waste. It is
recommended that inspecting agencies undertake a coordinated effort to
use the information contained elsewhere in this plan and their own
information to establish a priority system for regulatory enforcement.
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Cl/
Programs for inspection of hazardous materials and waste storage are -�
being administered by several local agencies. In addition, other local
agencies, such as sanitation districts and the Regional Water Quality
Control Board, may be gathering complementary information. It is
recommended that these agencies investigate the feasibility of developing
a comprehensive data base to incorporate the information gathered by
each agency. This data base should assist in the coordination of efforts of
the various agencies and provide better, more up-to-date information than
each agency would have available on its own.
CHAPTER 14 CONTAMINATED SITES
This chapter attempts to analyze the volumes of hazardous waste that
will be generated by cleanup efforts by the year 2000. The total amount
of hazardous waste estimated to be generated by site cleanups by the year
2000 is 3371 .8 tons, approximately 167 tons from the cleanup of leaking
underground tanks, . 3205 tons from the closure of toxic pits (based on a
worse case scenario), and an unknown amount from the cleanup of two
Bond Expenditure Plan sites. Appendix 14-1 lists the known co,itaminated
sites within San Luis Obispo County.
CHAPTER 15 SMALL QUANTITY GENERATORS (SOG)
This chapter discusses the hazardous waste management problems of
the small quantity generator and also contains estimates of the quantities
and types. of hazardous waste generated from Small Quantity Generators
(SQG). This information is used in Chapters Four, Five, and Six to estimate
current and projected hazardous 'waste. generation and Treatnient, Storage,
and Disposal Facility Capacity Shortfall.
Most of the local SQG are involved in service industries such as dry
cleaning, vehicle maintenance, printing, photographic processing, and
analytical and clinical laboratories. The construction industry forms
another large component of the local SQG.
The analysis and methodology used to estimate hazardous waste
produced by small quantity generators are likely to produce only a rough
approximation and overestimate the actual characteristics of San Luis
Obispo County's waste from SQG. An important objective of th?s first
planning effort is to develop improved estimation methods and data
sources that will be available for future plan updates. The more accurate
the understanding of the extent of the hazardous waste management
problem, the better the understanding of the treatment, storage and
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disposal facilities necessary to properly manage hazardous waste locally
and statewide.
While there are a large number of small quantity generators, SQG
usually produce a small percentage of the total hazardous waste from
industrial sources. However, despite their small contribution to the total
quantity of hazardous waste produced, the impact on human health and the
environment from the waste produced by SQG is a cause for concern for
the following reasons:
1 ) the characteristics of the waste produced by SQG can have the
potential to be very hazardous;
2) many of these generators may be involved in illegal disposal
practices;
3) due to the services that they provide, small quantity generators
tend to be located closer to reside:-I:ial neighborhoods than large
quantity generators.
A lack of information and understanding of regulations may be a
primary reason why the small quantity generators engage in disposal
practices that are not in compliance with regulatory ' requirements.
Whereas large companies can afford to hire consultants or special.
employees to deal with hazardous waste management and regulations, the
C SQG often_ cannot afford these special services. The high cost of proper
disposal is another major factor for r mall quantity generators. There are
usually economies of scale associated with disposal costs that are not
available for the SQG. Often while It may be technologically feasible to
treat or recycle hazardous waste onsite, the cost is often prohibitive for
the SQG because there is not enough volume to support the investment.
Due to the extremely competitive environment in which many small
businesses exist, they often cannot afford the cost of regulatory
compliance as it now exists.
A third reason for the improper disposal practices of many small
quantity generators is the lack of stringent enforcement of existing
regulations. Due to the large number of SQG it is very difficult for
regulatory agencies to monitor the disposal practices of small generators.
For small generators, the costs of regulaiiiry compliance often outweigh
the costs of noncompliance. There may be a perception among SQG that
their waste can be disposed of illegally without much risk of detection.
From the operator's perspective, it may be less costly for the small
quantity generator to dispose of waste illegally than to pay the costs of
;�. proper disposal.
i
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,
Table 15-1 summarizes the information in Appendix 15-3 and contains
the estimates of the types and quantities of hazardous waste generated by
local Small Quantity Generators according to the California. Waste Group
classification.
TABLE 15-1
CURRENT ESTIMATED SAN LUIS OBISPO COUNTY
SOG WASTE GENERATION BY CALIFORNIA WASTE GROUP
California Waste Group Quantity
(CWG#) (MT/YR. Metric Tons ner Year)"
1 . Waste Oil 1369.40
2. Halogenated Solvents 5.97
3. Non-Halogenated Solvents 97.59
4. Organic Liquids 4.73
5. Pesticides 27.12'
6. Dioxins 0
7. Oily Sludges 0
8. Halogenated Organic Sludges &Solids .88
9. Non-Halogenated Organic Sludges and Solvents 47.58
to. Dye and Paint Sludges and resins 25.44
11 . Metal-Containing Liquids 22.08
12. Metal-Containing Sludges .31
13. Cyanide and Metal-Containing Liquids 36.19
14. Non-Metallic Inorganic Liquids 21 .74
15. Non-Metallic Inorganic Sludges 0
16. Soil 0
17. Miscellaneous Waste 368.93
TOTAL, with waste oil 2028.54 MT/TR
In reviewing the way this figure was calculated, the Agricultural Commissioner's office
believes this estimate is unrealistically high based on proper pesticide container disposal
methods that result in the containers not being classified as waste.
The number of significant figures is for calculation purposes only and is not meant to reflect
the level of accuracy of the methodology.
Even though the above analysis is only a first attempt to characterize
the local SQG waste stream, the analysis may serve as an initial guide to
enforcement and data collection efforts by providing some
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indication of which industries are likely to produce the most waste and
what types of waste they produce. It may prove beneficial for local
governments to target certain industrial sectors of the local economy
with the intent to promote waste reduction, ensure regulatory compliance,
and improve the understanding of the County hazardous waste stream for
future plan updates.
It is more difficult to apply waste reduction techniques to Small
Quantity Generators than to industries that generate large quantities of
hazardous waste. Most SQGs lack both the financial resources needed to
invest in waste reduction equipment and the technical expertise often
necessary to implement waste reduction. Often the individual business
does not produce sufficient quantities of hazardous waste to make such
capital improvements cost effective. However, owners and operators of
small businesses need help to get started in compliance activities, .to .
assess feasibility of waste reduction and minimization programs, and to
become familiar with various recycling technologies.
The following local policies should provide a framework for addressing .
the hazardous waste management needs and problems of the small
quantity generator. The policies are based on the following goals:
C Goals
1 . In recognition of the serious potential threat to human health ,and
the environment posed by improper handling and disposal of the Hazardous
waste produced by small quantity generators, it is the goal of San. Luis
Obispo County to promote safe management practices and to emphasize
waste reduction among local small quantity generators.
2. Initial local programs for small quantity generators should be
designed to reach those categories of generators who are responsible for
the largest volumes of hazardous waste in order to achieve the greatest
waste reduction for the least cost.
3 . The priorities for waste management strategies are the following:
A) Source reduction;
B) Recycling;
C) Onsite treatment;
D) Transport to an offsite facility for recycling or treatment;
E) Disposal.
4. In order to contain the growth of the local hazardous waste
management problem, the County's goal is to ensure that waste
_ . 1 -29
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1
minimization and proper waste management practices for new county
businesses be considered as part of the project review and permitting
process.
5 . An important goal of this first planning effort is to develop
improved estimation methods and data sources that will be available for
future plan updates.
Objectives
1 . The County should assess the specific technical, financial and
informational needs of local small quantity generators in order to
determine the most beneficial programs to adopt to assist small quantity
generators.
2. The County should determine the location of small quantity
generators, the types and quantities of hazardous waste produced, the
types of industrial or business processes that are producing hazardous
waste and the current local waste management practices a.nd needs.
Policies
1 Measures and programs that promote reduction or minimization of
hazardous waste shall have priority over other wasste management
techniques.
2. In recognition of the fact that some waste . streams from small
quantity generators will require transport to recycling, treatment,
storage or disposal facilities, the County should encourage the
establishment of transfer stations at appropriate locations within the
County and should encourage the establishment of route collection
services for local small quantity generators of hazardous waste.
3 . Prior to the issuance of a land use permit for any new commercial
or industrial facility that will generate hazardous waste, the County or
city should determine whether proposed waste handling and disposal
practices will be in compliance with existing County, State and federal
regulations. A waste minimization plan should be required as part of the
County's or city's land use permit application.
CHAPTER 16 HOUSEHOLD HAZARDOUS WASTE (HHW)
This chapter outlines the, extent of the local household hazardous waste
problem and contains suggested goals, objectives, policies, programs, and
funding sources to use to address the local situation.
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i
Household hazardous waste (HHW) is that waste material from
- products and/or commodities purchased by the general public for
household use which have the potential to cause injury or illness to people
or the environment if improperly used, stored, or disposed of. Examples of
household hazardous waste include pesticides, paint supplies, antifreeze,
solvents, photographic chemicals, flea powders, cleaning compounds,
swimming pool chemicals, varnishes and automotive oils such as crank
case oils or brake fluids.
Household hazardous waste is often disposed of into sewer systems,
septic tanks or to local solid waste landfills with other household refuse.
The contamination of the solid waste stream by household hazardous
waste represents a potentially grave threat to the environmental integrity
of the typical solid waste landfill. A California Department of 'Health
Services' report to the Legislature suggests that households may be,, the;
single largest producer of hazardous waste at an estimated generation of
2-3 gallons of waste per year per person. When discharged into sewers,
hazardous waste may interfere with the bacterial, balance of the. sewage
treatment plant and result in the release of untreated or undertreated
sewage into rivers and oceans. When hazardous waste is disposed of in.
municipal landfills, they may accumulate and leach into -the .groundwater,
Cvent into the air as hazardous emissions, or disrupt the biological
decomposition of refuse.
The increased incidence of adverse health effects: and the
environmental damage resulting from the improper disposal of household
hazardous waste has heightened public awareness and is stimulating many
communities to take action. The most common activity undertaken by
local jurisdictions is to sponsor household hazardous waste collection
programs. These programs are intended to divert hazardous waste from
the typical municipal solid waste stream by providing residents with an
alternative to landfill burial or sewage disposal.
The experience of other jurisdictions shows the following:.
• HHW collection events are expensive. Typically, the average HHW
collection event costs approximately one dollar per person residing in
the jurisdiction while attendance at events typically is about one
percent.
• HHW collection events inevitably attract waste from the business or
industrial sector. Small-quantity generators of hazardous waste often
use these events as an opportunity to discard their waste at no costs to
1 -31 -- I
themselves. The lack of economical, available programs for small
industrial producers of hazardous waste leads them to use HHW events. _J
• Permanent collection facilities at landfills, wastewater treatment
plants, fire stations, local Environmental Health facilities, new or
existing hazardous waste treatment, storage, or disposal facilities
may offer a more cost-effective approach and augment periodic HHW
collection events.
• Recyclable waste oils and paints typically constitute about 50 to
65% of the hazardous waste collected at HHW collection events.
Separate collection programs for these two components of the HHW
stream may offer significant cost savings. The recycling arrangement
May require the local jurisdiction to buy back the paints recycled. The
recycled paint might be donated to local charitable organizations,
community service groups, or used for normal building maintenance
within the local jurisdiction.
• Public education efforts are a vital ingredient in any effective HHW
effort. Public education programs should encourage the public to:
1 . Buy non-hazardous products or use alternative methods when
there. is a choice;
2. If hazardous materials and products must be used, then
encourage the general public to buy only the amounts that they need,
and use up what they have in a safe manner; and
3. Encourage the public to give unneeded products to someone who
can use them instead of storing unneeded household hazardous
materials for extended periods of time or disposing of them
improperly.
Public education efforts can reduce the need for hazardous waste
facilities by promoting the use of non-hazardous product alternatives - or
by reducing the generation of household hazardous waste.
Goals
To ensure the safe disposal of household hazardous waste in order to
protect the public health and safety and environmental integrity of 'San
Luis Obispo County and the State of California .
To increase public awareness of the prevalence of the toxic products in
the home and every day life.
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�-, These goals can be achieved by:
1 . Establishing an integrated system of flexible, affordable,
environmentally sound programs for the management of HHW;
2. Establishing specific local programs for potentially recyclable
household hazardous waste such as waste oils, oil and water based
paints, and automotive batteries; and
3. Developing an educational program to promote the understanding
among the general public of the serious environmental and financial
consequences that are the result of the improper disposal of household
hazardous waste.
Policies
San Luis Obispo County shall encourage and promote the development of
Household Hazardous Waste Educational Programs.
San Luis Obispo County shall encourage and promote the development .of
household hazardous waste collection and temporary storage facilities
within the county.
Household hazardous waste management collection and temporary
storage facilities shall be required to be constructed in a manner which
minimizes any threats to the environment and the general public.
State Legislation for Funding HHW Programs
C AB 1809 (Tanner, 1985): Cities and counties .are authorized to
increase their solid waste collection fees in order to cover the costs for
the establishment, publicity and maintenance of household hazardous
waste management program.
AB 1744 (Wright, 1986): Public agencies and persons acting under
contract with a public agency(s), who are operating a household hazardous
waste collection program, are exempt from long-term liability per the
Federal Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA). The bill also exempts public agencies
from paying "California Superfund" taxes on waste collected as a part of a
voluntary hazardous waste collection program.
AB 2448 (Eastin, 1987): The bill authorizes grants of funds for
establishing collection -systems to ensure that hazardous waste including,
but not limited to, household hazardous waste, is not improperly disposed
of in local solid waste landfills.
The bill would authorize any county to adopt a schedule of fees to be
collected from each solid waste operator operating within the county or
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C
within a city in the county. The fees shall be established in an amount
sufficient to pay only those reasonable and necessary costs for the
preparation, operation, maintenance and administration of a program to
ensure that hazardous waste is not improperly disposed of in a solid
waste landfill.
Existing Household Hazardous Waste Management
San Luis Obispo County does not have mandatory garbage collection in
the unincorporated areas. Large, sparsely populated areas of the County
are not serviced by private garbage collection firms. Surcharges on
garbage collections, used to finance household waste management
programs, as authorized by AB 1809 (Tanner, 1985), would require the
residents of the incorporated areas of the county to subsidize a portion of
the. residents of the unincorporated areas. In effect, only the cities and a
portion of the residents of the unincorporated areas can be taxed through
garbage surcharges.
At the present time there is one county program for the management of
household pesticide hazardous waste. The program is operated by the San
Luis Obispo County Agricultural Commissioner's Office, The program
consists of a drop off location for household pesticide hazardous waste at
the Agricultural Yard on Kansas Avenue off Highway 1 , approximately 3
miles east of the City of San Luis Obispo The program became operational J
in the Spring of 1988. The program has sufficient funding for the disposal
of 64 drums of hazardous household pesticide waste at a Class I landfill.
ECOSLO of San Luis Obispo, a local non-profit recycling center also
accepts waste oil from the general public at no charge as a community
service. ECOSLO has the capacity to hold up to 1000 gallons of waste oil
in an above-ground storage tank. ECOSLO has developed a list of all
businesses within the county who will accept waste oils from the general
public and how much they charge for the service.
ECOSLO was awarded $10,000 of SB 959 (Hart, 1986) funds to expand
its waste. oil recycling program. Four additional dropsites will be
established in Arroyo Grande, Morro Bay, Atascadero and Paso Robles
where residents can dispose of waste oil at no charge. A substantial
amount of the grant monies will be used to promote the program and
educate the public of the need to dispose of waste oil properly.
The City of Morro Bay held a household hazardous waste collection
event on June 6, 1987. The program was financed through a one-time
1 -34
1
C, contribution from the City General Fund. The event had a participation of
1 .8% of the households in the city. Thirty-four 55-gallon drums of
hazardous waste were removed to Casmalia for disposal. The cost of this
one-time effort was approximately $11 ,000.
The existing programs in the county consist of one city-sponsored, one-
time collection event and one program for pesticides. It is apparent that
these existing efforts are inadequate to remove the hazardous waste
portion from the municipal solid waste stream. There is a growing gap
between the hazardous waste disposal services available and the demand
for such services that is being. created by legislative mandates against
present disposal practices.
Program Proposals
-Establish specific programs for potentially recyclable household
hazardous waste such as waste oils, paints, batteries, etc. These
programs should cost less because the waste is recyclable. This waste
represents about 65% of the HHW problem. '
-Establish a continuing program of public education. The collection and
distribution of information is a relatively low-cst effort that. should
Cbe emphasized in early efforts.
*Establish permanent household hazardous dr;:; off sites at all the
public . solid-waste landfills and transfer stations in the county. The
City of Santa Maria operates a hazardous waste dropsite at, the
municipal landfill at a cost of about $5,000 per month.
*Establish a series of county-wide household hazardous waste round-
up events. A county-wide collection event may attract, at a
participation rate of 1 .5%, about 1 ,100 households and cost
approximately $140,000. This estimate of the cost does not include
staff time and administration costs for organizing an event or the
costs to publicize an event.
*Require all new, offsite, multiuser, hazardous waste treatment,
storage or disposal facilities that serve the general - public to also
serve as household hazardous waste drop-off sites.
*Encourage the formation of a privately operated, door-to-door,
household hazardous waste collection system. This would offer a high-
cost disposal option for households willing to pay for the service.
1 -35
Cp - 3Z
Funding Options
The following are suggested funding options for local jurisdictions to
pursue in an effort to implement household hazardous waste management
programs.
• County-Wide Tax Assessment District: Establishing a county-wide
tax assessment district would provide a source of income through
assessment of-property taxes on residential property. A special tax
assessment requires approval by 2/3 majority of the voters and the
assessment is determined by the benefit received by each parcel.
• Increased Refuse Collection Fees: AB 1809 (Tanner, 1985)
authorizes local jurisdictions to increase solid waste collection fees
in order to fund the establishment, publicity, and maintenance of
household hazardous waste collection events. This may either be' done
by assessing each refuse collection company based on the total number
of accounts, residential and commercial, or based only on the
residential accounts. Residential garbage accounts only include single
dwellings; multi-unit dwellings such as apartments and condominiums
are classified as commercial accounts.
If a county-wide system of household hazardous waste collection
programs is not established, cities within the county may utilize this
funding mechanism in order to establish their own programs.
• Increased Solid Waste Landfill Fees: This funding option would add
a surcharge to landfill tipping fees for commercial and private
vehicles.
• Grants AB 2448 (Eastin, 1987) will provide State funding for HHW
programs. Guidelines and applications will be available for State
grants around July of 1989. The State grants will be available in late
1989 or early 1990. Additional grants may become available.
• Public/Private Donations and In-Kind Contributions (of Labor,
Materials and/or Equipment): Costs associated with a household
collection program can be substantially reduced through the
cooperation and financial support of businesses and civic groups.
• General Fund: This can include funding from the general tax revenue
of an incorporated city or a county or a combination of monies from
general funds from both incorporated cities and county.
1 -36
• Toxic Substances Fee or State Excise Tax: Such a fee or tax could
be imposed on household products containing toxic chemicals. The
monies could be used to finance safe disposal of HHW_ The disposal
costs would then be paid by those who profit from the use of such
products.
s
1 -37
ATTACHMENT 4
ENVIRONMENTALLY PREFERRED ALTERATIVE
The major elements of this alternative include the following:
Elimination of Study Areas 2 and 3 from the proposed general areas due to
geologic, hydrologic, and topographic constraints (Study Area 2), access
limitations due to existing traffic and/or road conditions (Study Area 2),
distance from the urbanized areas of the county where hazardous wastes are
generated (Study Areas 2 and 3) and proximity to urbanized area (Santa
Maria) which could be affected by toxic air emissions (Study Area 3);
- Reduction in size of Study Area 1 to include only the central-western
portion (approximately 450 acres) where the topography is more level (see
Figure XV.1) and where lands are located outside the 100-year flood plain.
- Restriction of Study Area 4 to storage/transfer facilities only.
- Reduction of the size of Study area 5 (to approximately 1,090 acres) to
include eastern portion (see Figure XV.4) and restriction to
storage/transfer facilities only.
- Restriction of Study Areas 7 and 8 to storage/transfer facilities only,
due to their current use as a landfill, isolation from other industrial
areas, and easy accessibility from urbanized portions of San Luis Obispo
County (via Highways 101, 46 and 227).
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ENGINEERING—SCIENCE